erm€¦ · we hope you find the above in order and please do not hesitate to contact erm should...

ERM Suite S005

17 The Boulevard

Westway Office Park

Westville, 3635

Durban, South Africa

Telephone: +27 31 265 0033

Fax: +27 31 265 0150

www.erm.com

Registered office Environmental Resources Management

Southern Africa (Pty) Ltd 1st Floor, Building 32 The Woodlands Office Park

Woodlands Drive, Woodmead 2148, Johannesburg, South Africa

Registered number: 2003/001404/07 VAT registration: 4780205482

Offices worldwide

Directors: Claudio Bertora

Urmilla Bob (Non-Executive) Leanne Gibbons

Thapelo Letete

Marinda Rasmussen

26 August 2020

Reference: 14/12/16/3/3/1/2015

ERM Reference: 0282731

Dear Interested and Affected Party

Subject: Traffic Impact Study for the Proposed Bhangazi Lodge, Kwazulu-Natal

Province- updating Specialist statement in line with the site layout revisions

As part of authority consultations, ERM held a meeting with the Department of Environment,

Forestry and Fisheries (DEFF) on 7 August 2020 to discuss a way forward with regard to the

update of Basic Assessment Report (BAR) following the appeals process. In the meeting, DEFF

indicated that if required, specialist studies are to be updated to reflect the changes in the site

layout, if no changes are required, then, it was advised that each specialist compile a letter (to be

submitted with the BAR), detailing the following :

• The review of the layout changes in relation to the area of specialization.

• Motivation as to why they believe that the revised layout will not change the identified

impacts and their significance.

Following the DEFF meeting, a query was sent to each of the project specialists on 7th August

2020, requesting updates to the specialist findings or a statement declaring that no changes

would be made. One of these specialists is Mr Andile Gqaji of AG Traffic and T Consultants (Ptv)

Ltd, who conducted the traffic study as part of the initial BA process.

In early communication with Mr Gqaji, it was indicated that the site layout changes would not

have an impact on the traffic study findings. This is due to there being no changes to the road

network that was assessed in the traffic study. As at the finalisation of the BAR however, Mr Gqaji

was not in a position to submit his updates due to there being a death in his family, following

which he had taken a leave of absence.

ERM will ensure that Mr Gqaji’s inputs and a new signed specialist declaration are submitted

with the final BAR.

We hope you find the above in order and please do not hesitate to contact ERM should you have

any questions.

Yours sincerely,

Stephanie Gopaul

Principal Consultant

environmental affairsDepartment:Environmental AffairsREPUBLIC OF SOUTH AFRICA

DETAILS OF THE SPECIALIST, DECLARATION OF INTEREST AND UNDERTAKING UNDER OATH

File Reference l,lumber:

NEAS Reference Number:

Date Received:

Application for authorisation in terms of the National Environmental Management Act, Act No, '107 of 1ggg, as amendedand the Environmental l[p4] 4lgqqsment (ElA) Regulations, 2014, as amended (the Resula1ons)

PROJECT TITLE

Kindly note the followingl

1' This form rnust always be used for applications that must be subjected to Basic Assessment or Scoping &Environmental lmpact Reporting where this Department is the Competent Authority.

2' This form is current as of 01 September 20'18. lt is the responsibility of the Applicant / Environmental AssessmentPractitioner (EAP) to ascertain whether subsequent versions of the form have been published or produced by theCompetent Authority. The latest available Departmental templates are available athttps ://www. envi ronment. gov.zaldocu ments/forms.

3. A copy of this form conterining original signatures must be appended to all Draft and Final Reports submitted to thedepartment for consideration.

4' All documentation delivered to the physical address contained in this form must be delivered during the officialDepaftmental Officer Hours which is visible on the Departmental gate,

5. All EIA related documents (includes application forms, reports or any EIA related submissions) that are faxed;emailed; delivered to Security or placed in the Departmental Tender Box will not be accepted, only hardcopysubmissions are acceoted.

DetailsPostal address:Depaftment of Environmental AffairsAttention : Chief Director: I ntegrated Envi ronmental AuthorisationsPrivate BagM4VPretoria

0001

Physical address:Department of Environmental AffairsAttention : Chief Di rector: I nteg rated Environ mental AuthorisationsEnvironment House473 Steve Biko Fload

Arcadia

Queries must be directed to the Directorate: Coordination, Strategic Planning and Support at:Email : [email protected],za

Details of Specialist, Declaration and Undertaking Under Oath

Page '1 of 3

AG Traffic and T Consultants (Ptv) LtdContribution level (indicate 1

to 8 or non-compliant)

BSc (Honours): TProfessional Eng i neeri ng tecn notog iit / 2tl 1 020zu

5 Trafford Avenue, Dawncliffe, WESTVILLE5 Trafford Avenue, Dawncliffe, WESTVILLE

ttc.co,za

1, SPECIALIST INFORMATION

Specialist Connpany Name:

B-BBEE

Spercialist name:Specialist Clualifications:

Professionalaffil iation/reg istration :

Physical address:

Postal address:

Postal code:

Telephone:

E-mail:

2, DECLIIRATION BY THE SPECIALIST

l, Andile Gqaji, cleclare that -

I act as the independent specialist in this application;

I will perfornr the work relating to the application in an objective manner, even if this results in views and findinosthat are not favourable to the applicant;

I declanr that there are no circumstances that may compromise my objectivity in per.forming such work,

I have e'xpefiise in conducting the specialist report relevant to this application, including knowledge of the Act,Regulations and any guiclelines that have relevance to the proposed activity;

I will comply with the Act, Regulations and all other applicable legislation;

I have no, and will not enlSage in, conflicting interests in the underlaking of the activity;I undeftake Io disclose to the applicant and the competent authority all material information in my possession thatreasonably has or may have the potential of influencing - any decision to be taken with respect to the application bythe competent authority; and - the objectivity of any report, plan or document to be prepared by myself forsubmission to the competent authority;

all the particulars furnished by me in this form are true and conect; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F ofthe Act.

AG Traffic and Tnansportation Consultants (pty) Ltd

e

o

a

c

a

a

a

a

e

Name of Company:

12 June 2019

Date


Page 2 of 3

3. UNDERTAKING UNDER OATH/ AFFIRMATION

AG Traffic and Transportation Consultants (Pty) Ltd

I, Andile Gqaji, swear under oath I alfirm that all the information submitted or to be submitted for the purposes of this

Name of Company

12 June 2019

,-pJ"-signature of the commissionerbf qdF€SfVf

1,F gd j

$J"" t


Page 3 of 3

April 2016

Traffic Impact Statement Report

of the

Proposed Bhangazi Heritage Site

Development

Prepared by:


Cell: +27(0) 82 786 4690 Fax: +27(0) 86 524 1038 Email: [email protected]

Prepared for: ERM Southern Africa (Pty) Ltd Unit 6 | St Helier Office

Park | Cnr St Helier Road & Forbes Drive | Gillitts | 3610 |

Durban | South Africa

1


1. BACKGROUND INFORMATION

AG Traffic and Transportation Consultants (Pty) Ltd were appointed by ERM Southern Africa (Pty) Ltd

to undertake a Traffic Impact Statement (TIS) for the Proposed Bhangazi Heritage Site Development in the Cape Vidal area. The objective of this statement is to discuss the traffic impact of the proposed development on the existing road network. Figure 1 shows the location of the Bhangazi Heritage Site, marked as A and B in the Cape Vidal area. The Site Development Plan (SPD) is shown in Figure 2 overleaf.

Figure 1: Location of Bhangazi Heritage Site within Cape Vidal.

2


According to the information provided, the proposed development will have the following land uses as traffic generators:

10 x 2 bed units;

8 x 4 bed units;

4 x 2 bed units; and 350 m2 Restaurant (including kitchen and toilets).

Figure 2: Site Development Plan.

The accommodation section of the development is expected to generate external trips. The estimated seating capacity at the restaurant will be about 50 guests. The restaurant, based on its location is not expected to generate as many external trips, nevertheless if it does, it is not expected to generate more than 20% of the external trips and the remaining 80% will be internal trips. As the worst case scenario all trips to be generated by the proposed development will be treated as external trips and will be added and analysed accordingly. 2. TRIP GENERATION RATE

The documents “South African Traffic Impact and Site Traffic Assessment Standards and Requirements Manual, TMH 16, Volume 2, Version 1.0, August 2012” and “South African Trip Data, TMH 17, Volume 1, Version 1.0, September 2012” published by the Committee of Transport Officials (COTO) were used to estimate the number of trips that will be generated by the proposed development.

A

3


For the purpose of undertaking an analysis for the accommodation part of the development, each 2 bed unit will be taken as representing a room, therefore, the proposed development will have 30 rooms. The 350 m2 in total will consist of restaurant, a kitchen and toilets. The areas for kitchen and toilet are unknown to be deducted and as the worst case scenario the 350 m2 in size will be used to conduct an analysis for the restaurant. It must also be noted that since the proposed development site is situated within an existing establishment, therefore, there are current trips that are visiting the establishment that could be deducted from the primary trips to be generated by the proposed development. All trips to be generated by the proposed development will be treated as primary trips to be analysed and reported as worst case scenario. Anticipated trips that are to be generated by the proposed development are shown in Table 1 below. Table 1: Trip Generation for the Proposed Bhangazi Heritage Site Development

In Out Total In Out Total

Lodging 30 Room 0.30 0.40 5 4 9 6 6 12

Restaurant 350 100 m2 0.75 11.80 2 1 3 16 25 41

7 4 12 22 31 53

Total Trips Generated

AM Peak Hour PM Peak Hour

Trip Gen

Rate PM

Peak Hour

TOTAL

Trip Gen

Rate AM

Peak Hour

Land Use Type Size Unit

Therefore, it is anticipated that in total, the proposed development will generate approximately 12 trips during the AM peak hour and 53 trips during the PM peak hour as indicated in Table 1above. 3. EXISTING ROAD NETWORK There is one existing access point to the Cape Vidal area. It is anticipated that this access point will continue to serve the development site. The existing access road to the Bhangazi Heritage Site is along the access road towards Cape Vidal. The main entrance and exit point as indicated in Figure 2 will exclusively serve the guests to the development site. Service/delivery vehicles will exclusively use the entrance/exit marked “A” as indicated in Figure 2. The access gate to Cape Vidal is via an unnamed road which is 2.6 km from the town of St Lucia. This unnamed road has one lane in each direction and in some sections it has a narrow shoulder and in some has a gravel shoulder. The road has about 3.5 m lane width. Figure 3 shows the road network within the study area.

Mtubatuba/N2

Access point to

Cape Vidal

To the Sea

To St Lucia

Figure 3: Road network.

“A”

4


From the gate to Cape Vidal, the existing access road that provides access towards Bhangazi Heritage Site is a tarred road which is approximately 20 km. From this tarred road, the current state of the road that directly goes to Bhangazi Heritage Site is a gravel road which is winding with sharp curves in some sections. 4. EXISTING CONDITIONS In order to determine the likely traffic impact that the proposed development would have on the existing road network, it was necessary to ascertain the current traffic performance of the traffic system within the vicinity of the development site. The closest intersection (marked with “A” in Figure 3) within the development site is the intersection of the unnamed road (towards St Lucia and Cape Vidal) with a road leading up to the sea. This intersection is priority controlled and is in a form of a T-junction with north-south movement being prioritised. No public transport facilities such as bus/taxi shelters are provided on either side of this unnamed road. A negligible number of pedestrians were observed along the road. Also no pedestrian infrastructure such as sidewalks are provided on either side of the unnamed road. The pictures shown below were taken at this intersection.

Figure 4: View to the south (looking towards St Lucia).

Figure 5: View to the east (looking towards the Sea).

5


4.1 Existing traffic volumes Manual traffic counts were undertaken on Wednesday, 13 May 2015. These traffic counts were undertaken at the nearest intersection to the development site due to its close proximity to the development site. From these traffic counts, the AM and PM peak hours were determined to be:

AM peak hour – 07:45 to 08:45

PM peak hour – 16:15 to 17:15 The traffic counts were used to determine the level of traffic at affected intersection in the vicinity of the development site. The 2015 AM and PM peak hour background traffic counts are shown in Figures 7 and 8, respectively.

The development generated traffic was then distributed based on the distribution patterns as the 2015 background traffic. The development generated traffic was then combined with the 2015 background traffic for the AM and PM peak hours. The results of the combined traffic volumes are shown in Figures 9 and 10.

Figure 7: 2015 AM Peak Hour Traffic Volumes. Figure 8: 2015 PM Peak Hour Traffic Volumes.

16 2

Sea

9 5 1

9

St Lucia

Bhangazi H

erita

ge S

ite

8 1

Sea

13 4 1

5

St Lucia

Bhangazi H

erita

ge S

ite

Figure 6: View to the north (looking towards the gate to Cape Vidal).

6


5. CAPACITY ANALYSIS Intersection analysis was performed using aaSidra computer software in order to determine the Volume / Capacity (v/c), Delay in Seconds and Level of Service (LOS) at the respective affected intersections in the vicinity of the development site. The summary of the capacity analysis results for both the AM and PM peak hours is shown in Table 2 below. Table 2: 2015 AM and PM Background Without and With Development Traffic Analysis Results

V/C Delay LOS V/C Delay LOS V/C Delay LOS V/C Delay LOS

South 0.010 1.2 A 0.009 3.1 A 0.017 1.2 A 0.024 2.0 A

East 0.004 10.7 B 0.009 10.7 B 0.004 10.7 B 0.010 10.8 B

North 0.005 0.3 A 0.010 0.9 A 0.017 0.5 A 0.030 0.9 A

Overall 0.010 1.6 A 0.010 4.0 A 0.017 2.0 A 0.030 3.3 A

Approach

Bhangazi Heritage Site/St Lucia Intersection

2015 AM and PM Peak Hour Without Development Traffic 2015 AM and PM Peak Hour With Development Traffic

AM Peak Hour PM Peak Hour AM Peak Hour PM Peak Hour

The site observations and the analysis results as shown in Table 2 show that during both 2015 AM and PM peak hours, the intersection analysed is currently operating satisfactorily with no approach worse than LOS B with plenty of spare capacity available. Table 2 also shows that after the development generated traffic has been added to the 2015 AM and PM background traffic volumes, the intersection analysed will continue to operate satisfactorily with still no approach worse than LOS B with negligible increase in delays and still plenty of spare capacity available. Therefore, no upgrades to the roads or existing intersections as a result of the proposed Bhangazi Heritage Site development, are required. 6. PARKING 6.1 Parking Requirements

The document “South African Roads Board: Parking Standards (2nd Edition)”1 published by the National Department of Transport (NDoT) was used to determine the number of parking bays required to meet the parking demand that will be generated by the Proposed Bhangazi Heritage Site Development.

Figure 9: 2015 AM Peak Hour plus Development

Traffic Volumes.

Figure 10: 2015 PM Peak Hour plus Development

Traffic Volumes.

12 1

Sea

20 4 1

5

St Lucia

Bhangazi H

erita

ge S

ite47 2

Sea

31 5 1

9

St Lucia

Bhangazi H

erita

ge S

ite

7


Using the applicable parking rate of 1 bay per room and 6 parking bays/100 m2 for the restaurant, it is therefore required that a minimum of 30 and 21 parking bays be provided for the rooms and restaurant, respectively. However, the restaurant will serve both internal and external trips and it is assumed that majority of the trips to the restaurant will be internal. Accordingly, it is proposed that instead of providing 21 parking bays for the restaurant, 10 parking bays be provided to meet the external trips and some internal trips demand as it is assumed that the majority of the internal trips to the restaurant will be made by walking. Therefore, in total at least, 30 and 10 parking bays should be provided on site to meet the parking demand for the rooms and restaurant, respectively. 7. CONCLUSIONS The objective of this report was to determine the traffic impact as a result of the Proposed Bhangazi Heritage Site Development on the existing road network and to identify the most appropriate upgrades, if required, to alleviate such an impact. It is, therefore, concluded that:

It is anticipated that the proposed development will not generate a substantial number of trips;

The intersection analysed operates satisfactorily with no approach worse than LOS B before and after the development generated traffic has been added;

The adjacent road network will be able to accommodate the trips generated by the proposed development;

Two access points will serve the development site, one for the guests and one for the service/delivery vehicles; and

In total at least, 30 and 10 parking bays should be provided on site to meet the parking demand for the rooms and restaurant, respectively.

8. RECOMMENDATIONS It is, therefore, recommended that the Proposed Bhangazi Heritage Site Development Traffic Impact Statement Report be approved based on the following:

No external upgrades to the roads or existing intersections required as a result of this proposed development; and

Two access points to serve this proposed development and be taken directly off the Main Road to Cape Vidal, as shown in Figure 2.

In total at least, 30 and 10 parking bays should be provided on site to meet the parking demand for the rooms and restaurant, respectively.

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VVAATT RReeggiissttrraattiioonn NNuummbbeerr:: 44664400220055226688

PPOO BBooxx 5500991100,, MMuussggrraavvee RRooaadd,, 44006622

tteell:: 008833 770033 22999955,, eemmaaiill:: jjoonn@@eennvviirrooccoonnssuulltt..ccoo..zzaa

Our Ref: 1503/JM 20th August 2020

ERM

Suite S005, 17 The Boulevard, Westway Office Park Westville 3635

Attn: Stephanie Gopaul Dear Stephanie

VISUAL IMPACT ASSESSMENT FOR THE PROPOSED BHANGAZI LODGE, KWAZULU-NATAL PROVINCE Further to your query of the 7th August 2020, we confirm that as long as the proposed changes do not result in removal of sections of the tree canopy or structures including roofs extending higher than the tree canopy, the assessment and findings contained in the Visual Impact Assessment dated June 2017 are still valid and remain unchanged. Should you or the Competent Authority have any further queries, please contact the undersigned. Yours faithfully

Jon Marshall ENVIRONMENTAL PLANNING AND DESIGN

enYironn"lentatr affai rsDepartment.Environmental AffairsREPUSLIC OF SOUTH AFRICA

DETAILS OF THE SPECIALIST. DECLARATION OF INT=REST AND UNDERTAKING UNDER OATH

File Reference Number:


Date Received:

Application for authorisation in terms of the National Environmental Management Act, Act No. 107 of 1998, as amendedand the Environmental lmpact Assessment (ElA) Regulations. 2014, as amended (the Regulaiions)

PRCJECT TITLE

Bhangazi Lodge

Kindly note the following:

1. This form must always be used for applications that must be subjected to Basic Assessment or Scoping &

Environmental lmpact Repofting where this Depafiment is the Competent Authority.

2. This form is current as of 0'1 September 2018, lt is the responsibility of the Appiicant / Environmental Assessment

Practitioner (EAP) to ascertain whether subsequent versions of the form have been published or produced by the

Competent Authority. The iatest avaiiable Departmental tempiates are availabie ai

https :/lwww.envi ron ment. gov.zaldocu mentslforms.

3, A copy of this form containing original signatures must be aopended to all Draft and Final Reports submittec to the

department for consideration

4. All documentation delivered to the physical address contained in this form must be delivered during the official

Departmental Officer Hours which is visible on the Depafimenial gate.

5. All EIA related documents (includes application forms, reports or any EIA related submissionsi that are faxed;

emailed; delivered to $ecurity oi" placed in the Departmental Tender Box will not be accepted, only hardcopy

submissions are accepted.

Departmental DetailsPostal address:Department of Environmental AffairsAttention: Chief Director: lntegrated Environmental AuthorisationsPrivate 3agX447Pretoria

0001

Fhysical address:Depafiment of Environmental AffairsAttention: Chief Director: lntegrated Environmental AuthorisationsEnvironment House

473 Steve Biko Road

Arcadia

Queries must be directed to the Direciorate: Coordination, Strateoic Planning and Suoport at:

Email:EIAAdmi


Page 1 oi 3

1, SPECIALIST INFORMATION

Specialist Company Name:

B.BBEE

Speciaiist name:

Specialist Qualifications:Professional

aff i I iationlreg istration :

Physical address:

Postal address:

Postal code:

Telephone:

E-mail:

TECI-P.RATIOru BY TiNE SPECIALIST

t, Jon MarshalI oeciare that -


I will perform the work relating to the applicaiion in an objective ma'nner, even if this resulis in views and findings

that are not favourabie to the applicant;

I declare that there are n0 circumstances that may compromise my objeciivity in performing such work;

I have expertise in conducting the speciaiist reporl relevant to this application, including knowledge of the Act.

Regulations and any guidelines that have relevance to the proposed activity;

I wili comply with the Act, Regulations and all other applicabie legislation;

I have no, and will not engage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material information in my possession that

reasonably has or may have the potential of influencing - any decision to be taken with respect to ths application by

the competent authority: and - the objectivity of any report, plan or documenl to be prepared by myself for

submission to the competent authority;

all the particulars furnished by me in this form are true and correct; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of

the Act.

Environnrental Planning and Design cc

a

G

G

3

3

3

a

a

s

Contribution ievei {indicate 1

to 8 or non-comPiiant)

4 Percentage

Procuremenirecocnition

I Ii/larehall

CnartereO Member of the Landscape lnstitute (UK),

Registered Professional Landscape Architect (South Africa)'

IAIA

33 Askew Grove, ilurban, 4001

PO Box 509'10, Musgrave Road, Durban

4Uoln^il\rUtl

Fax

083 703 2395

ion@envi roconsuli.co,za

Signature of the Special

Name of Company:

21 st Lugust 2020

Date

Details o? Specialist, Declaration and Undertaking Under OathPage 2 ol 3

this aoolicaiion is true anc c0rrect

3, UNDERTAKING UNDER OATI.I' ATFIRMATIOi{

i Jon Marshall . swear under oath I affirm thal all the inforrnatlon submitied 0r t0 be

Environmental Planning and Design CC

Name o{ Companv

l:p f fVc. lz"za,t

J3L'

{frWtrs'r(dof the lammtssioner cf Oaths

SCUIt i'F*; .,r. - .;l':r iE;tffi.CDER/ 1-r. N_- 1 n;;il;;r*"=

DURBAN iiNNEOUN

20?fi -fi8- ? m

OUTER PERIMETER

9!"8-AfB ft: r *.r ro.--; s r nr Hr s*

Detaiis cf Specialisi, Decla;"ation and Undertaking l..lnciei' lai;iFage 3 ol 3

submitted for the

Signatur* of tno

environmenml affairsDBpartmsfit:Environmonial AffcirsBEFUELIC OF SOUTI{ AFRICA

DETAILS OF THE SPECIALIST, DECLARATION OF INTEREST AND UNDERTAKING UNDER OATH

File Reference Number:


Date Received:

Application for authorisation in terms of the National Environmental Management Act, Act No, 107 of 1998, as amended

and the Environmental lmpact Assessment (ElA) Regulations, 2014, as amended (the Regulations)

L

2.

PROJECT TITLE

Bhangazi Cultural Heritage Lodge Development within iSimangaliso Wetland Park World Heritage Site

Kindly note the following:

This form must always be used for applications that must be subjected to Basic Assessment or Scoping &

Environmental lmpact Reporting where this Department is the Competent Authority.

This form is current as of 01 September 2018. lt is the responsibility of the Applicant / Environmental Assessment

Practitioner (EAP) to ascertain whether subsequent versions of the form have been published or produced by the

Competent Authority, The latest available Departmental templates are available at

https //vwwv,environ ment,gov.zaldocu ments/forms.

A copy of this form containing original signatures must be appended to all Draft and Final Repofts submitted to the

department for consideration.

All documentation delivered to the physical address contained in this form must be delivered during the official

DepartmentalOfficer Hours which is visible on the Departmentalgate,

All EIA related documents (includes application forms, reports or any EIA related submissions) that are faxed;

emailed; delivered to Security or placed in the Departmental Tender Box will not be accepted, only hardcopy

submissions are accepted.

Departmental Details

Postal address:Department of Environmental AffairsAttention: Chief Director: lntegrated Environmental AuthorisationsPrivate Bag X447

Pretoria0001

Physical address:Department of Environmental Affairs

Attention: Ch ief Director: lntegrated Environmental Authorisations

Environment House

473 Steve Biko Road

Arcadia

Queries musi be directed to the Directorate: Coordination, Strategic Planning and Support at:

Email:ElAAdmi

Details of Specialist, Dedaration and Undertaking Under OathPage '1 of 3

1. SPECIALIST INFORMATION

Specialist Company Name:

B-BBEE

Specialist name:

Specialist Qualifications:Professional

affiliation/reg istration :

Physical address:Postal address:

Postal code:

Telephone:

E-mail:

DECLARATION BY THE SPECIALIST

l, Jonathan Marshall , declare that -


I will perform the work relating to the application in an objective manner, even if this results in views and findings

that are not favourable to the applicant;

I declare that there are no circumstances that may compromise my objectivity in performing such work;

I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act,

Regulations and any guidelines that have relevance to the proposed activity;

I will comply with the Act, Regulations and all other applicable legislation;

lhave no, and willnotengage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material information in my possession that

reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by

the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for

submission to the competent authority;

allthe particulars furnished by me in this form are true and conect; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of

the Act.

Environmental Planning and Design

a

a

a

a

a

a

a

a

a

Environmental Planning and Desiqn

Contribution level (indicate Ito 8 or non-compliant)

4 Percentage

Procurementrecoqnition

Jonathan Marshall

Dip LA

Chartered Member of the Landscape lnstitute (UK).

Registered Professional Landscape Architect (South Africa).

IAIA

33 Askew Grove, Glenwood, Durban, 4001

PO Box 50910, Musgrave Road, Durban

4062 Cell:

Fax:

083 703 2995

ion @enviroconsu lt,co.za

Name of Company:

18th June 2019

Date

Details of Specialist, Dedaration and Undedaking Under OathPage 2 of 3

3, UNDERTAKING UNDER OATH/ AFFIRMATION


l, Jonathan Marshall , swear under oath / affirm that all the information submitted or to be submitted for the purposes

Name of Company

18h June 2019

&r\t- ru * \q'

H AF IqiCAi.{ POLICE SERVICEOPERATIONAL RESPCNSE SERVICES

PORT OF ENTRYDURBAN HARBOUR

rfi$ -fl6- I I

OUTER PERIMETER

SUID AFR;K4rrrlliE

Date

Details of Specialist, Dedaration and Undertaking Under OathPage 3 of 3

THE PROPOSED BHANGAZI LODGE DEVELOPMENT

WITHIN THE ISAMANGALISO WETLAND PARK, KWAZULU

NATAL

VISUAL IMPACT ASSESSMENT

SCOPING REPORT

MAY 2015

Prepared by:


P.O. Box 2122,

Westville

3630

Tel: 031 266 8241

Email: [email protected]

Prepared for:

ERM Southern Africa (Pty) Ltd

Unit 6 St Helier Office Park

Cnr St Helier Road & Forbes Drive,

Gillitts,

3610

Tel: 031 767 2080

Fax: 031 764 3643

Email: [email protected]

Bhangazi Visual Impact Assessment, Scoping Report, April 2015. Page 2

TABLE OF CONTENTS

1. INTRODUCTION ................................................................................................................................................................. 4

1.1 Documentation ............................................................................................................................................................... 4

1.2 Project Team and Experience ........................................................................................................................................ 4

1.3 Site Location and Project description ............................................................................................................................. 4

1.4 The nature of Visual Impact ........................................................................................................................................... 6

1.5 Guidelines to be utilised and their relevance ................................................................................................................. 7

1.6 Scoping Objectives ........................................................................................................................................................ 7

2. ZONE OF THEORETICAL VISIBILITY ............................................................................................................................. 11

3. EXISTING LANDSCAPE ................................................................................................................................................... 13

3.1 Landscape Protection .................................................................................................................................................. 13

3.2 Landscape Character ................................................................................................................................................... 13

3.2.1 Landform and Drainage..................................................................................................................................... 13

3.2.2 Nature and Density of Development ................................................................................................................. 14

3.2.3 Vegetation Patterns ........................................................................................................................................... 15

3.2.4 Landscape Character Areas, Visual Absorption Capacity and Significance ..................................................... 16

3.3 Significance of the Landscape Character Areas .......................................................................................................... 17

4. AFFECTED AREA AND LIKELY VISUAL RECEPTORS ................................................................................................. 22

4.1 Affected Area ............................................................................................................................................................... 22

4.2 Identified visual receptors ............................................................................................................................................ 22

4.3 Likely significance of visual receptors .......................................................................................................................... 23

5. POTENTIAL VISUAL ISSUES ASSOCIATED WITH THE PROPOSED DEVELOPMENT .............................................. 28

5.1 General ........................................................................................................................................................................ 28

5.2 Possible Change in Landscape Character................................................................................................................... 28

5.3 Likely implications for Visual Receptors ....................................................................................................................... 28

5.4 Planning and Design Considerations ........................................................................................................................... 28

6 RECOMMENDED METHODOLOGY FOR ASSESSMENT ................................................................................................... 31

6.1 Requirements in accordance with the Western Cape Guidelines................................................................................ 31

6.2 Detailed Methodology .................................................................................................................................................. 32

6.2.1 Identification of issues raised in scoping phase, and site visit .......................................................................... 32

6.2.2 Description of the receiving environment and the proposed project ................................................................. 32

6.2.3 Establishment of view catchment area, view corridors, viewpoints and receptors ........................................... 33

6.2.4 Indication of potential visual impacts using established criteria ........................................................................ 33

6.2.5 Inclusion of potential lighting impacts at night ................................................................................................... 34

6.2.6 Description of alternatives, mitigation measures and monitoring programmes. ............................................... 34

6.2.7 Review by independent, experienced visual specialist (if required).................................................................. 34

7 CONCLUSIONS ...................................................................................................................................................................... 35

8 REFERENCES ....................................................................................................................................................................... 36


TABLES

Table 1 Coordinates of the proposed site

Table 2 Proposed assessment criteria for landscape degradation

MAPS

Map 1 Site Location

Map 2 Site Context

Map 3 Initial Development Proposal

Map 4 Zone of Theoretical Visibility

Map 5 Landform

Map 6 Vegetation and Ridgelines

Map 7 Landscape Character Areas

Map 8 Visual Receptors

PHOTOGRAPHIC PLATES

Plate 1 St Lucia Valley Landscape Character Area

Plate 2 St Lucia Valley Landscape Character Area

Plate 3 Enclosed Wetland Valley Landscape Character Area

Plate 4 Enclosed Wetland Valley Landscape Character Area

Plate 5 Bhangazi Lake Landscape Character Area

Plate 6 Bhangazi Lake Landscape Character Area

Plate 7 View from Bhangazi Lake Area Receptor

Plate 8 View from Main Access Road Linear Receptor

Plate 9 View from Track South of Lake Bhangazi Linear Receptor

Plate 10 View from View Point SE of Lake Bhangazi Point Receptor

Plate 11 View from Bhangazi Bush Lodge Point Receptor

Plate 12 View of the Forest Edge that will be Impacted by Development


1. INTRODUCTION

1.1 Documentation

This Visual Impact Assessment (VIA) study will form part of the Basic Assessment

environmental application that is being undertaken for the proposed development

of the Bhangazi Lodge by ERM on behalf of the Bhangazi Community Trust.

In terms of the amended National Environmental Management Act (NEMA) Act No.

107 of 1998, the proposed development requires environmental authorisation. A

key impact to be assessed comprises the visual impact that the facility will have on

surrounding areas.

1.2 Project Team and Experience

Jon Marshall qualified as a Landscape Architect in 1978. He is also a certified

Environmental Impact Assessment Practitioner of South Africa. He has been

involved in Visual Impact Assessment over a period of approximately 30 years. He

has developed the necessary computer skills to prepare viewshed analysis and

three dimensional modelling to illustrate impact assessments. He has undertaken

visual impact assessments for major buildings, mining, industrial development,

mining and infrastructure projects and has been involved in the preparation of

visual guidelines for large scale developments.

1.3 Site Location and Project description

The proposed development is located approximately 1.75km inland and southwest

of Cape Vidal. It is situated on the south eastern bank of Bhangazi Lake.

The site falls within the within the iSimangaliso Wetland Park which is a World

Heritage Site as indicated on Maps 1 and 2, Locality and Site Context

respectively.

The site falls within the Umkhanyakude District Municipality

The project is proposed within the Bhangazi Heritage Site (Concession Area A & B

that was given to the Bhangazi Community Trust as part of a land claim settlement.

Concession area A has been marked for development, Concession area B is a no

development zone. The development is proposed in Concession Area A.

The site lies adjacent to the road to Cape Vidal which is a popular tourist

destination.

Initial project planning indicates that the project may be comprised of;

Development of 16 tourist accommodation units located along the lake

shore but within existing mature trees. The units will reflect the local

vernacular from which it is assumed that natural materials will be utilised for

external finishes. It has been assumed that each unit will have a footprint

area in the order of 50m2 and will be single storey. A maximum height of

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6m has been assumed which allows 3m for the accommodation level and

3m for the roof structure.

A restaurant that will also be located close to the lake shore, within existing

mature trees. The restaurant will have external finishes similar in nature to

the tourist accommodation units. It has been assumed that the restaurant

will have a footprint area in the order of 300m2 and will be single storey. A

maximum height of 6m has been assumed which allows 3m for the

accommodation level and 3m for the roof structure.

Five staff quarters that will be located away from the lake shore close to

existing staff quarters to the north east of the site. It has been assumed

that these buildings will an individual footprint area of 50m2 and will be

single storey. A maximum height of 6m has been assumed which allows 3m

for the accommodation level and 3m for the roof structure. They will be

located close to the existing through road to Cape Vidal.

An Interpretation Centre to be used for education, as an introductory facility

for visitors, accommodation check in, advertising and booking of activities

such as guided tours, game drives, guided walks, and a small shop.

A day visitor and community gathering area located away from the lake

shore. This will consist of an open area with social facilities including braai

and picnic facilities and a swimming pool. It is assumed that canopy trees

will be retained and maintained for shade and that ground level vegetation

will largely be removed for circulation.

Visitor parking (27 bays), chalet parking (21 bays) and bus parking (2 bays)

to be located away from the lake shore. These will consist of cleared areas

largely located beneath the existing tree canopy or where trees have to be

removed or canopy non-existent new tree planting will augment existing

vegetation. A new informal access track / road will be constructed to link

chalet parking areas.

Staff parking (3 bays), Lodge parking (2 bays) and game drive vehicle

parking (1 bay) located close to the staff accommodation.

A small service and delivery area close to the staff accommodation.

An initial layout as provided by the applicant is attached as Map 3. It should be

noted however that at the time of reporting this layout was under review with the

intention of providing greater exposure to Lake Bhangazi for the accommodation

units and the restaurant.

The geographical co-ordinates of approximate centre point of the proposed site are

indicated in Table 1:

Table 1: Coordinates of the proposed site

South 28˚ 08’ 19.73”

East 32˚ 32’ 38.54”

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1.4 The Nature of Visual Impact

Visual impacts may relate to a general change in the character of an area or in the

change in a specific view for a person or group of people.

Visual impacts can be positive or negative and a degree of subjectivity is required

to in deciding this point. The approach of any visual assessment should be to as

objectively as possible describe an expected landscape and as far as is possible

reflect the likely majority view regarding positive / negative aspect of an impact.

This can be difficult particularly in South Africa due to different values and cultures

associated with various sectors of the population. For example, poorer sectors of

the population are possibly more concerned with the productive nature of a

landscape than its appearance, whereas the wealthier sectors might be more

concerned with scenic value particularly as it is associated with property values. If

possible the values and opinions of all impacted sectors of the community should

be considered.

General change to a landscape area might have greater or lesser significance

subject to;

Numbers of people that might use the landscape,

The level of protection afforded the landscape,

The rarity of the landscape

In terms of change to a specific view this might be defined as either visual intrusion

or visual obstruction.

Visual intrusion is a change in a view of a landscape that reduces the quality of

the view. This can be a highly subjective judgement, subjectivity has been

removed as far as is possible in this assessment by classifying the landscape

character of each area and providing a description of the change in the

landscape that will occur due to the proposed development.

Visual obstruction is the blocking of views or foreshortening of views. This can

generally be measured in terms of extent.

More often than not such an impact will be a combination of intrusion and

obstruction. Obstruction can be measured in terms of the extent of an existing view

that is screened by a development. However, judging intrusion again requires a

degree of subjectivity. It is however possible to relate this judgement to the

manner in which proposed change would impact on the use or enjoyment of an

area which again requires an understanding or local values.

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1.5 Guidelines to be Utilised and their Relevance

There are numerous guideline documents for visual impact assessment, most of

which have a common approach. This assessment will be undertaken in accordance

with:

The Government of the Western Cape Guideline for Involving Visual and

Aesthetic Specialists in EIA Processes (2005) (Western Cape Guidelines), which

is the only relevant local guideline, setting levels of input subject to the likely

sensitivity of a landscape as well as the scale and nature of a proposed

development. It therefore provides a basis for justification and agreement of a

required scope of work.

The Landscape Institute and Institute of Environmental Management and

Assessment (UK) Guidelines for Landscape and Visual Impact Assessment

(third edition, 2013) which provides detail of international best practice and

technical methodology.

Together these documents provide a basis for the level and approach of a VIA as

well as the necessary tools for assessment and making an assessment legible to

stakeholders.

1.6 Scoping Objectives

This Scoping Study identifies and evaluates potential visual impacts associated with

the various aspects of the proposed Project. In terms of the EIA Regulations,

feasible and reasonable alternatives must be assessed within the Scoping Study.

The characteristics of a scoping exercise are as follows:

Feasible and reasonable alternatives are identified and selected for further

assessment;

Important characteristics of the affected environment are identified;

Significant issues that are to be examined in the assessment procedure are

identified; and

It provides the basis for determining terms of reference for the assessment

stage.

Based on a brief assessment of the landscape and likely receptors and in

accordance with the Western Cape Guidelines, this scoping study will identify key

concerns or issues relating to potential visual impacts arising from the project, and

to determine boundaries and parameters for visual input.


2. ZONE OF THEORETICAL VISIBILITY

The Zone of Theoretical Visibility (ZTV) is defined as “a map usually digitally

produced showing areas of land within which a development is theoretically

visible”.

The ZTV has been identified in order to focus the study on the area that is likely to

be impacted by the proposed development.

ZTV for the proposed development have been assessed using Arc Spatial Analyst

GIS (Map 4). The assessment is based on terrain data that has been derived from

satellite imagery. This data was originally prepared by NASSA and is freely

available on the CIAT-CCAFS website (http://www.cgiar-csi.org). Permission for

use of this data in this project has been obtained from the project administrator

(Appendix I).

The GIS Assessment also does not take the curvature of the earth into account. In

order to provide an indication of the likely limit of visibility due to this effect a

universally accepted navigational formula (appendix II) has been used to

calculate the likely distance that the proposed structures might be visible over. This

indicates that in a flat landscape a structure 6m high could be visible at a distance

of approximately 9km. This buffer is indicated on Map in order to indicate the likely

limit of visibility.

It should be noted that existing vegetation which is likely to have a significant

modifying effect on the visibility of the proposed development has not been taken

into account in the definition of the ZTV.

The mapping indicates that;

The proposed development could be visible to the southern sector of Lake

Bhangazi as well as the southern and western shores. It is however only likely

to be visible over small areas of the eastern shore.

The proposed development could be visible to large sections of the enclosed

valley to the south of Lake Bhangazi.

The proposed development is only likely to be visible intermittently to high

ground to the south and east.

The majority of the ZTV is located within the limit of Approximate Limit of

Visibility. Mapping does indicate that it could be visible to small sections of the

western shore of Lake St Lucia. However due to distance this is highly unlikely.

The study should therefore focus on the ZTV within the Approximate Limit of Visibility (9km)

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3. EXISTING LANDSCAPE

It is possible that landscape change due to the proposed development could impact the

character of an important landscape area.

Importance can be derived from specific features that can relate to urban or rural settings.

They might include key natural, historic or culturally significant elements.

Importance might also relate to landscapes that are uncommon or under threat from

development.

Generally the most significant natural areas are afforded a degree of legal protection such

as National Parks and Reserves; however, they might also have local significance and not

be protected.

This section describes the types of landscape that may be impacted, indicates likely

degree of sensitivity and describes how the landscape areas are likely to be impacted.

3.1 Landscape Protection

The affected area falls within the iSimangaliso Wetland Park which is a World Heritage

Site. World Heritage Site Status implies the highest order of landscape protection.

Nomination criteria for inscription as a World Heritage Site included;

Ecological processes

Superlative natural phenomena and scenic beauty

Biodiversity and threatened species

The IUCN Technical Investigation prior to inscription also highlighted the integrity of the

landscape as key to the inscription decision.

Therefore anything that could potentially erode this integrity either from within the

protected area must therefore be considered as having negative impact.

3.2 Landscape Character

Landscape character is defined as “a distinct, recognisable and consistent pattern of

elements in the landscape that makes one landscape different from another”.

Landscape Character is a composite of a number of influencing factors including;

Landform and drainage.

Nature and density of development.

Vegetation patterns.

3.2.1 Landform and Drainage

Refer to Map 5. The proposed site area is located immediately inland of the coastal dune

cordon. Due to a band of cohesive Berea Red sands adjacent to the coast, the steeply

shelving sea floor, strong NE / SW prevailing wind system and strong wave action, steeply

sloping beaches and tall, steeply sloping sand dune system has developed to the east of


the proposed site. The tall dune reaches heights of between 90 - 150m amsl in the vicinity

of the proposed site.

The tall dune cordon provides a significant barrier to drainage of areas to the north and

west which results in drainage pans and perhaps greater confluence of systems that might

be expected in areas in areas where the coastal due is less of a barrier. This has resulted

in the formation of Lake St Lucia and associated wetlands as well as a number of more

minor water bodies including Bhangazi Lake which is immediately to the west of the

proposed site.

Smaller water bodies are fed by ground water more than surface water drainage. These

water bodies form in depressions close to the western side of the dune cordon. Lake

Bhangazi located close to the foot of the coastal dune cordon with a relatively small

surface catchment area is one of the larger examples of this.

Lake St Lucia is a more major system and this has forms an estuary that drains through

the dune to the south of the town of St Lucia.

Immediately inland of the coastal dune system soils are predominantly sandy in nature

resulting in a series of small undulating dunes, seepage areas and wetlands. This area is

backed by a band of Zululand Group siltstone and sand stone which forms a higher ridge

on the western edge of the Wetland Park.

Landform and drainage therefore contributes to the landscape character in the following

way;

The Berea Red sands on which the tall dunes to seaward of the proposed site and

minor north south ridgelines within the immediate hinterland provide a tall

backdrop to the area.

The sands of the coastal plain in which the site is located a low undulating area

within which the wetland landscape that the iSimangaliso is famous for has formed.

The taller siltstone / sandstone ridge inland of the wetland park provide the inland

limit of the wetland landscape.

3.2.2 Nature and Density of Development

Development within the study area can be divided into the following types;

Occasional small scale tourism and service orientated development within

the Wetland Park. This includes;

A small area of service buildings in the vicinity of the proposed site.

Bhangazi Lodge which is located on the north western shore of Lake Bhangazi.

This is comprised of four accommodation units and a small service area.

Visitor facilities including camping and caravan park areas at Charters Creek,

Fanies and Lister Point on the western shore of Lake St Lucia. These facilities are

located in excess of 10km from the proposed development. Whilst these facilities

are not likely to impact on or be impacted by the proposed development, they

do highlight the consistency of approach to small scale visitor facilities within the

Park.

Urban development that is generally located on higher areas inland and to the south

of the site. This development is located some distance (more than 25km) from the

proposed site. It includes the settlement of Hluhluwe and St Lucia. Due to distance,

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these settlements are unlikely to impact on or be impacted on by the proposed

development.

Roads and tracks in the vicinity of the proposed site are generally low key. The main

access road that runs past the site linking St Lucia to Cape Vidal is a two lane

surfaced road. Other minor roads and tracks are generally single lane and are either

unsurfaced or concrete surfaced.

Development therefore contributes to the landscape character of the area surrounding the

proposed development in the following manner;

Natural vegetation is generally sufficiently dense to ensure that the occasional

small scale tourism and park service development areas generally only influence

landscape character in their immediate vicinity. It is however possible that lakeside

development could be visible over a wider area and that light from these areas

could erode the feeling of being in a wilderness environment particularly from the

shores of the lake.

Urban development is generally some distance from the proposed development

area and intervening topography and natural vegetation are likely to minimise its

influence on landscape character.

Roads and tracks within the area are relatively minor and whilst they do present an

obviously man made element within a largely natural environment, outside the

vicinity of the road or track they have a minimal influence on local landscape

character.

3.2.3 Vegetation Patterns

Refer to Map 6. The majority of vegetation in close proximity to the site comprised of

natural vegetation including;

Northern Coastal Forest that covers the dune slopes and minor ridgelines. From

reference to KwaZulu Natal Vegetation Type Descrption (C R Scott Shaw and B

Escott) this is comprised of dense thickets of 5-6 m up to tall forests with the

canopy reaching 15 m with well-developed shrub layer and very poorly developed

ground layer.

Subtropical Freshwater Wetlands which according to Scott Shaw and Escott are

typically located within flat topography supporting low beds dominated by reeds,

sedges and rushes, water logged meadows dominated by grasses. Found typically

along edges of often seasonal wetlands.

Maputaland Wooded Grassland which is generally found in the flat landscape of the

Maputaland coastal plain supporting coastal sandy grasslands rich in geoxylic

suffrutices, dwarf shrubs, small trees and very rich herbaceous flora.

Swamp Forest located on slightly elevated ground within and beside wetlands.

The vegetation types indicated contribute to landscape character of the area in the

following way;

The fact that the majority of vegetation in the area is natural helps to provide the

wilderness feeling that is so important to retain within the Wetland Park.

The Northern Coastal Forest that covers the higher ridgelines and dune slopes

providing a dramatic backdrop to the site. This vegetation type on minor inland

ridgelines also reinforces the screening ability and helps to compartmentalise the

landscape.

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Bands of Swamp Forest on slightly elevated land beside wetlands also provides tall

screens that help to compartmentalise the landscape.

Freshwater wetlands provide open vistas through the landscape.

Wooded Grasslands in the vicinity of the proposed site are reasonably open with

occasional trees and shrubs only.

3.2.4 Landscape Character Areas, Visual Absorption Capacity and Significance

Landscape Character Areas (LCAs) are defined as “single unique areas which are the

discrete geographical areas of a particular landscape type”.

The affected landscape can generally be divided into the following LCAs. Because the

affected area has a predominantly natural character, these are largely defined by

topography and vegetation. Development in the form of small scale visitor facilities / park

service areas and roads and tracks have a very localised modifying effect

Lake Bhangazi. This LCA is enclosed by the tall coastal dune an coastal forest to the

east and north east, by a minor ridgeline reinforced with Coastal Forest and Coastal

Belt vegetation that runs to the west and north west of the lake and by a natural bund

that retains the lake and is also covered by dense coastal vegetation to the south.

This combination of landform and vegetation combine to produce an enclosed

landscape with the lake as a focal point. Once inside this space, views of other

landscape character areas are not possible.

Anything that is developed on the shores of the lake has the potential of being visible

to the lake and lake shores opposite the development. This area therefore has a low

visual absorption capacity.

Subject to height and the extent and nature of vegetation that needs to be cleared,

development away from the lake shore is likely to be screened by dense forest

vegetation. This landscape therefore has a high visual absorption capacity for small

scale low development.

The higher that development occurs either on the minor ridgelines to the west or the

major coastal dune to the east, the less the visual absorption capacity that is likely to

be afforded by the landscape.

Enclosed Wetland Valley. This area falls immediately to the south of Lake Bhangazi.

This LCA is comprised of an area of wet grassland that is enclosed by a minor ridge

line with swamp forest and Coastal Belt vegetation to the west, the tall dune slope

with costal forest to the east and the small berm to the south of Lake Bhangazi that is

reinforced with dense Coastal Belt vegetation to the north. This has created an

enclosed landscape from which views of other LCAs are difficult if not impossible to

see. From within views are often possible from one side of the LCA to the other across

wet grasslands.

Any development that occurs within this LCA, even at lower levels is likely to be

visible over much of the LCA. Development at lower levels however is unlikely to be

visible to other LCAs. For development at lower levels, this LCA might therefore be

considered to have medium visual absorption capacity.

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However, the higher that development occurs either on the minor ridgelines to the

west or the major coastal dune to the east, the less the visual absorption capacity

that is likely to be afforded by the landscape.

St Lucia Valley. This LCA is comprised of Lake St Lucia, its surrounding wetlands and

low valley slopes. Uninterrupted long and broad views are possible within this LCA

over the lake and surrounding wetlands.

3.3 Significance of the Landscape Character Areas

The St Lucia Valley LCA is a large scale open natural lake and wetland landscape and is

the image of the Park that most visitors are likely to remember. It is therefore critical that

visual impacts associated with development are minimised within this LCA.

The Wetland Valley LCA is a relatively enclosed natural landscape. The only development

obvious are the minor tracks and the road that run through it. The LCA provides an

important link between the main St Lucia Lake and Bhangazi Lake From the site visit it is

obvious that the animals that are so obvious on Lake Bhangazi utilise this LCA extensively

for refuge and as their primary habitat area. This LCA is overlooked from the main visitor

access. The impact of increased development in this LCA could put at risk the profusion of

wild life that is visible on Bhangazi Lake.

The Lake Bhangazi LCA is a relatively small enclosed landscape that is focused on the

body of open water. The large dune to the east and the covering of dense forest that

surrounds it helps to provide a dramatic visual experience. The expanse of open water

attracts wildlife and makes viewing animals of all kinds from the lake shore easy. The

dense vegetation surrounding the lake also serves to screen development that has already

occurred ensuring that the LCA from most viewpoints retains its natural appearance.

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ST LUCIA VALLEY

Open, large scale natural landscape within which extensive views from one side of

the valley to the other are possible.

ENCLOSED WETLAND VALLEY

Enclosed natural wetland landscape, views are possible over wet grassland areas

but are enclosed by vegetation and minor ridgelines.

BHANGAZI LAKE

Bhangazi lake attracts wildlife from surrounding areas. It is enclosed by the tall

dune to the east, minor ridgelines to the west, a small berm to the south and

encircled by dense vegetation.

PLATE 1 PLATE 2

PLATE 3 PLATE 4

PLATE 5 PLATE 6


4. AFFECTED AREA AND LIKELY VISUAL RECEPTORS

Visual Receptors are defined as “individuals and / or defined groups of people who

have the potential to be affected by the proposal”.

4.1 Affected Area

From the site visit it is obvious that existing vegetation which in areas is dense will

have a significant modifying effect on the visibility of the proposed development,

including;

The dense coastal vegetation on the berm to the south of Lake Bhangazi

effectively blocks views of the lake and lower sections of the coastal dune

and minor ridgelines that surround the lake.

Wooded grassland and swamp forest to the west of Lake Bhangazi

effectively blocks the view that might otherwise be possible between the

sections of minor ridgeline to the west of the study area. This prevents

longer range views across the wetland area towards Lake St Lucia.

Tall coastal forest on the ridgelines and slopes to the north and east of

the proposed development area will effectively block intermittent views of

the proposed development that might otherwise be possible to the north

of the study area.

The modifying effects noted above result in the likelihood of the proposed

development largely being screened from the wider landscape and likely to only be

visible from a limited area focused on the southern and western sectors of the Lake

Bhangazi LCA.

It is highly unlikely that the development will be visible from the St Lucia Valley.

The proposed development could be intermittently visible to elevated areas of the

coastal dune to the north, east and south.

The potentially affected area of the ZTV is indicated on Map 8: Visual Receptors.

4.2 Identified visual receptors

It is possible that an area might be sensitive due to an existing use. The nature of

an outlook is generally more critical to areas that are associated with recreation,

tourism and in areas where outlook is critical to land values.

This section is intended to highlight possible receptors within the landscape which

due to use could be sensitive to landscape change. They include;

Area Receptors which include;

o Lake Bhangazi which could be used for boat trips for visitors.

Linear Receptors which include main routes through the area. It is likely that

these routes will be mainly used by tourists. They include;

o The main access road that runs from St Lucia to Cape Vidal. From the site

visit, the site is only visible from a short area of this road either side of the

viewpoint listed under Point Receptors below.

o The access track that runs across the berm to the south of Lake Bhangazi.

Whilst this was closed at the time of reporting, it seems likely that this will

be opened up again to at least guided walks. From the site visit, currently


views of the lake are only visible from the viewpoints indicated under Point

Receptors. Views towards the site are not visible from the track side of the

berm. They would hoever be visible if vegetation on the berm were to be

cleared.

o The minor road access to Bhangazi Lodge that runs to the west of the

Wetland Valley, within the main St Lucia Valley and along the western

shore of Lake Bhangazi within the Bhangazi Lake LCA.

Point Receptors that include;

o Two viewpoints that are located on the berm to the south of Lake

Bhangazi. These are located at either end of the berm.

o A viewpoint that has been located on the St Lucia to Cape Vidal

access road overlooking Lake Bhangazi from the south.

o The small Bhangazi Lodge development on the north western shore

of Lake Bhangazi.

It is noted that there is a possible future tourism development that is being planned

for the south western edge of Bhangazi Lake.

Visual receptors that may be sensitive to landscape change associated with the

proposed development are indicated on Map 8: Visual Receptors.

4.3 Likely significance of visual receptors

Significance of change to a view for a visual receptor is likely to relate to use.

Uses such as tourism and recreation areas are likely to rely on the maintenance of

an outlook for successfully attracting guests and users. Housing areas could depend

on outlook for the enjoyment of the area by residents and for maintaining property

values. A route that is particularly important for tourism may also be dependent on

outlook for the maintenance of a suitable experience for users.

The assessment indicates that all identified visual receptors are important or

potentially important for tourism activities. They are all therefore significant. It is

suggested however that maintaining a natural edge to Bhangazi Lake is probably

the mots important consideration. Without this, it is likely that the wilderness

experience for visitors to the lake will be lost. It is also likely wildlife will negatively

impacted if the lake edge is disturbed to any extent. This will also impact

negatively on the attraction and enjoyment of visitors.

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Area Receptor –Bhangazi Lake

Views of natural forest on the lake shore are seen at the moment from the lake.

Linear Receptor – Main Access Road (St Lucia to Cape Vidal)

Views of the Bhangazi Lake surrounded by natural forest are possible from a short

section of this road either side of a formal viewpoint providing a completely natural

view.

SITE AREA

PLATE 7

PLATE 8

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Views of natural forest on the lake shore are currently seen from the lake.


Linear Receptor – Track to South of Lake Bhangazi

Views of the Lake Bhangazi LCA are currently screened by the area of forest that

has established on the berm immediately to the south of the lake.

Point Receptor – View Point to South East of Lake Bhangazi

Views of the lake surrounded by natural forest are seen from existing viewpoints.

PLATE 9

PLATE 10


Point Receptor – Bhangazi Bush Lodge

Views of the lake surrounded by natural forest are seen from the Lodge.

PLATE 11


5. POTENTIAL VISUAL ISSUES ASSOCIATED WITH THE PROPOSED

DEVELOPMENT

5.1 General

The mapping indicates that;

1. The proposed development is likely to be visible from a relatively small area

focused on the Lake Bhangazi LCA and is unlikely to impact on any other

LCA with the exception of 2.

2. It may be possible for proposed development to impact on a small section of

the St Lucia to Cape Vidal Road around the location of a formal viewpoint

approximately 2km to the south of the proposed development.

5.2 Possible Change in Landscape Character

Subject to the extent and location of development it is possible that the natural

character of Lake Bahngazi could be eroded.

Subject to the extent of vegetation clearance it is possible that the development

could create built elements that detract from the view of the natural landscape as

viewed from the St Lucia to Cape Vidal Road.

5.3 Likely implications for Visual Receptors

Lake Bhangazi LCA is an enclosed landscape which due to the lake attracts a

profusion of wildlife from surrounding areas. It is therefore an obvious place for

watching and enjoying a variety of game from relatively close quarters.

Subject to extent and location, disturbance of the natural vegetation on the edge of

Lake Bhangazi, the development could be visible to the southern and western

shores of the lake. This could erode the current natural appearance of the lake

shore and could also discourage wild life into the area. If this should occur the

experience of visitors who are attracted to the Park for its natural environment and

natural scenic beauty would be negatively impacted.

Also subject to the extent of clearance and the nature of the proposed development

it is possible that it could result in built elements being visible within an otherwise

natural view from the St Lucia to Cape Vidal Road.

5.4 Planning and Design Considerations

The developer needs to develop sufficiently to ensure that the facility is

economically viable, attractive to visitors and results in maximum exposure of

visitors to key views and wildlife associated with the Lake. However if the lake

frontage is over developed this could result in loss of wildlife from the area and the

appearance of development within what is a pristine natural environment.

A delicate balance between development and the natural environment therefore

needs to be struck. The locating of development behind the tree line and the

minimising of vegetation clearance are critical in achieving this balance.

It may be possible to develop immediately behind the tree line and below the tree

canopy on the lake frontage, however, the lay eye indicates that the forest edge is

dense and it is likely that trees and lower storey vegetation will have to be

removed to allow this to occur.

Given that the forest edge is dynamic, the removal of trees could result in the

ingress of weed species and the unplanned loss of additional vegetation over time.

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The ecologist’s input regarding the likely stability of the forest edge profile given

the possible removal of vegetation will be critical in assessing the likely impact over

time.

The restaurant and pool deck is probably the elements of largest concern due to

the size and exposure that will probably be required. Locating it to the north of the

site will minimise its impact on the north west shore possibly hiding it from the

Bhangazi Bush Lodge but it will potentially be visible from the southern shore.

Locating it to the south will minimise impact on the southern shore and south west

corner but it will potentially be visible to the western shore. Placing it central on the

site will mean that it is potentially visible from both the western and southern

shores.

The careful location of units below the forest canopy and the minimising of

clearance of trees and understorey vegetation are critical to minimising visual

impacts; the closer that the planned units are to the lake shore and the greater the

extent of clearance that occurs, the greater the risk that the development will be

obvious from the lake and from the main access road. In order to manage this it is

recommended that a detailed tree survey including accurately locating the all

canopy trees is undertaken. The impact can then be considered in detail.

Careful consideration will also have to be given to lighting, the use of colour and

reflective surfaces

Lighting particularly close to the lake edge has the potential to be seen on

the lake and on the opposite lake shore. Even a single exposed bulb could

change the wilderness impression during hours of darkness. Added to this is

that one of the attractions of the wilderness is the night sky which can be

enjoyed with significantly greater clarity than in light polluted developed

areas. Therefore there is a need to design lighting carefully.

Contrasting and complementary colour has the ability to be highly obvious

within a natural landscape. Colours should be visually recessive such that

the structures blend into the background landscape. It may be necessary to

undertake tests to ensure that the desired effect is achieved. It I soften

assumed that green will be most effective in achieving this as the

surrounding landscape is predominantly green. It is often forgotten that the

colour of the landscape changes over time and that it is made up of a large

variety of shades of green. The use of a uniform green therefore often

stands out against this variety. The use of black or mid to dark grey is often

the most successful colour that blends into a variety of natural landscapes.

The use of any reflective material must also be undertaken carefully.

Reflective finishes particularly on a roof could make the development

obvious from the look out on the main access road and on surfaces close to

the lake frontage could make the development obvious to the opposite lake

shore particularly when the sun is low in the west in the late afternoon.

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Existing Forest Edge that will be impacted by development.

Development will require removal of some existing vegetation. Roof structure of

existing development is just visible. Additional clearance could increase the impact

of development on Bhangazi Lake and erode the wilderness experience.

PLATE 12


6 RECOMMENDED METHODOLOGY FOR ASSESSMENT

6.1 Requirements in accordance with the Western Cape Guidelines

The criterion recommended by the Western Cape Guidelines for justification of level

of input for a VIA is the expected level of visual impact. This categorisation is

derived from the following matrix;

The categorisation of development is indicated below;

From the assessment undertaken it is apparent that the proposed project falls into

a category 2 development as it might be classed as a low key resort.


Given the fact that the proposed development will impact on a protected area, in

accordance with the guidelines, the proposed development might be expected to

have high visual impact for which a Level 4 Assessment is required.

A level 4 assessment requires the following input;

Identification of issues raised in scoping phase, and site visit;

Description of the receiving environment and the proposed project;

Establishment of view catchment area, view corridors, viewpoints and

receptors;

Indication of potential visual impacts using established criteria;

Inclusion of potential lighting impacts at night;

Description of alternatives, mitigation measures and monitoring programmes.

3D modelling and simulations, with and without mitigation.

Review by independent, experienced visual specialist (if required).

The Guidelines also indicate that if moderate impact is anticipated then the level of

assessment should be Level 3.

A Level 3 Assessment is practically the same as Level 4 but without the

requirement for 3D modelling and simulations.

Current information is highly schematic and is not adequate to assess impacts in

detail, however, when development plans are available they should reviewed to see

if new roof lines are likely to break through the existing natural tree canopy or the

existing tree line on the lake edge. In order to undertake this assessment a

detailed tree survey will also be necessary to overlay on the development plan. If

after undertaking this assessment it is obvious that development is unlikely to be

visible, a Level 3 Assessment is recommended as it is would be pointless to

undertake simulations.

However, should it be found that the proposed development is likely to be visible

either through the treeline to Lake Bhangazi or through the canopy to the St Lucia

to Cape Vidal Access Road then a Level 4 Assessment must be undertaken.

6.2 Detailed Methodology

The following methodology will be used in preparation of the VIA report.

6.2.1 Identification of issues raised in scoping phase, and site visit

Likely issues have already been identified in this scoping analysis. These issues will

be verified from a site visit as well as response from stakeholders to the scoping

documentation.

6.2.2 Description of the receiving environment and the proposed project

The receiving environment has been described and categorised. This has been

verified from a site visit.

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6.2.3 Establishment of view catchment area, view corridors, viewpoints

and receptors

Zones of theoretical visibility and visual receptors have been established from a

GIS analysis that has been verified during a site visit.

Subject to detailed planning, viewpoints will be confirmed during a further site visit.

6.2.4 Indication of potential visual impacts using established criteria

Areas of likely visual impacts have been identified and described from this scoping

exercise. They relate to degradation of the natural character of the landscape

surrounding Bhangazi Lake, include;

1. Subject to the extent and location of development it is possible that the

natural character of Lake Bahngazi could be eroded.

2. Subject to the extent of vegetation clearance it is possible that the

development could create built elements that detract from the view of the

natural landscape as viewed from the St Lucia to Cape Vidal Road.

It is proposed that the criteria detailed in Table 2 are used for the assessment.

These impacts will be investigated in detail during the assessment stage. In order

to undertake this detailed assessment the following information will be necessary;

1. A detailed tree survey of the affected area recording the location (x, y and z

coordinates), approximate height, approximate spread and condition of

trees in addition to their species.

2. The footprint area of proposed units overlaid onto the tree survey.

3. Descriptions of the proposed units including heights and finishes of walls

and roofs.

Table 2, Proposed Assessment Criteria for Landscape Degradation

1 INTENSITY OF IMPACT Rating

1a The introduction of new landscape elements that

will be obvious and will erode an existing natural

landscape character.

High Impact Intensity

1b The introduction of new landscape elements that

could be visible but are unlikely to be obvious to

the majority of visual receptors.

Medium Impact

Intensity

1c The introduction of new landscape elements that

are unlikely to be visible to identified visual

receptors.

Low Impact Intensity

2 SIGNIFICANCE OF IMPACT Rating

2a All identified impacts will affect a formally

protected landscape

High Significance

3 POSITIVE / NEGATIVE IMPACT Rating

3a Loss of rural natural characteristics Negative impact

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6.2.5 Inclusion of potential lighting impacts at night

The impact of lighting at night will be included in the assessment using the above

criteria. Potential light impacts include;

1. It is possible that light pollution from the proposed development could

reduce the natural wilderness character of the surrounding landscape during

hours of darkness.

In order to assess this it will be necessary for the design team to confirm Lighting

proposals and proposed mitigation measures to minimise light pollution to the

adjacent lake.

6.2.6 Description of alternatives, mitigation measures and monitoring

programmes.

No alternatives have been identified for this project other than the “no go”

alternative which will be considered in the assessment.

Mitigation and monitoring measures will be developed during the preparation of the

VIA report.

6.2.7 Review by independent, experienced visual specialist (if required).

Confirmation of this requirement is needed.


7 CONCLUSIONS

The brief assessment undertaken indicates that there is potential for the proposed

development to change the character of the Bhangazi Lake landscape. This

however is subject to detailed planning and the extent of disturbance that will be

needed to develop the site.

The main risks are associated with the proposed development include;

Clearance of canopy trees resulting in roof lines and development being

visible from higher levels on the St Lucia to Cape Vidal Road.

Clearance of vegetation and development being visible from the landscape

surrounding Bhangazi Lake.

Light from the development being visible to the surrounding landscape

during the hours of darkness.

The affected landscape has the highest level of protection that it is possible within

South Africa and it is recognised as having international importance due to its

“Superlative natural phenomena and scenic beauty”. Ensuring that the proposed

development does not impact on this existing character is therefore critical.

Whilst visual impacts are indicated as likely to be low, any erosion of the existing

natural landscape character through development is likely to affect the current

status.

It is noted that existing development on the site is just visible to the Lake which

illustrates the need for careful planning, as additional clearance and development

could exacerbate this current impact.

As careful planning is required and impacts are likely to relate to both the nature of

proposed development and the clearance of vegetation, it is recommended that a

detailed tree survey including location, height, spread, condition and species of

trees is undertaken in order that the impact of clearance can be accurately

assessed.

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8 REFERENCES

Guidelines for involving visual and aesthetic specialists in EIA processes,

Author; Bernard Oberhozer. Published by the Provincial Government of the Western

Cape: Department of Environmental Affairs and Development Planning, 2005

Guidelines for landscape and visual impact assessment (third edition),

authors; the Landscape Institute and Institute of Environmental Assessment and

Management, published by E & FN Spon, 2013.

Methods of Environmental Impact Assessment, edited by; Peter Morris and

Riki Therivel, Oxford Brookes University, UCL Press, 2000.

Manual of Environmental Appraisal, UK Department of Transport, 1992

Australian Capital Territory (Planning and Land Management Act 1988,

Amendment No 18 (ACT Telecommunications Plan) 1995.

Visual Impact Assessment Guidebook, Second Edition. Province of British

Colombia. January 2001

Consortium of Spatial Information web site, http://www.cgiar-csi.org/

Transport and Main Roads, State of Queensland (Department of Transport and

Main Roads), June 2013


APPENDIX I, PERMISSION TO UTILISE CGIAR DEM DATA

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APPENDIX II, CALCULATION OF VISUAL HORIZON

Bhangazi Lodge Basic Assessment - Specialist Report Updates

SPECIALIST FOREST ECOLOGIST REPORT

Dr Derek Berliner

Eco-logic consulting

For

Environmental Resources Management Southern Africa Pty Ltd

Aim

ERM is in the process of updating the Bhangazi Cultural Lodge Basic Assessment Report (BAR) in light

of the proposed amendments to the impact footprint resulting in a generalised decrease in impact

on the Greenfields sections , these changes are listed in the table below

Proposed changes to impact footprint

Mitigation Measure Nett Result

Remove proposed new access road, in

favour of using the existing access road to

the fishing camp area.

No longer need to clear an extent of 200m2

(forested area) for the access road

alignment.

Relocate restaurant and pool complex from

forest zone to disturbed fishing camp zone.

No longer need to clear an extent of 350 m2

(forested area) for the restaurant and pool

complex.

Following above, no requirement for new

access road leading to restaurant complex.

No longer need to clear an extent of 200 m2

(forested area) for the service road

alignment.

Reducing the size of the proposed 2 and 4

bed chalet units from 75 m2 to 50 m2 and

40 m2 respectively.

Potentially cleared area reduced from 1350

m2 to 970 m2 (footprint of raised decks, not

necessarily clearance of forest canopy).

Forest infrastructure limited to chalets and

boardwalks only, all on raised timber decks.

Reduction of impact on undergrowth.

In this regard I have ben asked to :

1. Review of the updated site layout plan in relation to the affected specialist area. Attached to this email is the updated layout for your information.

2. Updating of the impact assessment in light of the layout changes. 3. Updating the specialist report, detailing the updates and indicating the sections of the report

where the updates have been made.

Comments

These changes do not impact significantly on the result of this report, but are in line with the

recommendations made in the initial report to reduce the impact on the greenfield section by

reducing the total number of accommodation units as well as shifting the restaurant and pool

complex from the green fields section to the disturbed areas of the fishing camp. This will make a

significant reduction in the need to disturb the forested area.

From section 4 (4th paragraph) of the report : “ To reduce the footprint and to ensure a reasonable

space between units, it is recommended that accommodation units be reduced by two units. Unit 7a

has two large Marula trees that should not be cut down, while unit 7b , falls too close to the main

complex to fit in comfortably. In addition, changes to shift the restaurant complex and pool area

from the Greenfields section to the existing disturbed areas of the fishmen as camp need to be

considered”

Conclusion

These changes are welcomed and do not significantly alter the conclusion of this report, but are in

line with its recommendations

Dr Derek Berliner

Eco-logic consulting

12 August 2929

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SPECIALIST FOREST ECOLOGIST REPORT

VEGETATION SURVEY FOR BASIC ASSESMENT FOR THE PROPOSED

LAKE BHANGAZI LODGE

Dr Derek Berliner Eco-logic consulting

For

Environmental Resources Management Southern Africa Pty Ltd

08 November 2018

(updated 12 August 2020)

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Table of Contents Executive summary .................................................................................................................... 3

1 Introduction ........................................................................................................................ 4

1.1 Understanding of brief ................................................................................................ 4

1.2 Legal context ............................................................................................................... 4

1.3 Layout and geo-referencing of lodge accommodation units ....................................... 5

1.4 Tasks and approach used ............................................................................................. 6

2 Description of vegetation communities potentially impacted by the proposed lodge ....... 8

3. The status of plant species of conservation concern occurring, and potentially occurring

in the study areas. ..................................................................................................................... 11

4. The integrity of the vegetation communities ................................................................... 12

5. Can the forest be considered as riparian vegetation ? ..................................................... 14

6. Description of the number and type of trees impacted by the proposed development. .... 17

6.1 Forested section (greenfield)......................................................................................... 17

6.2 Disturbed areas, with existing structures................................................................... 18

7. Concluding remarks .......................................................................................................... 21

References ................................................................................................................................ 24

Appendix 1: Recorded tree and vine species list ..................................................................... 25

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Executive summary The Bhangazi Community Trust proposes to develop a cultural tourism lodge within the designated area of the Bhangazi Heritage Site. A large portion of the project area has already been disturbed as an old fishing holiday camp. There is an extension of that footprint area, required for the development of the Bhangazi lodge accommodation units, into the neighbouring forest (greenfield section).

As part of the Basic Assessment report, a specialist study has been requested that addresses the requirement of DAFF to determine the extent of damage to the forest, (quantity and species of trees). To asses this impact, the accommodation units were assumed to have a 10-meter square footprint. The layout plan, as provided by the client, was used with google earth, to obtain the general position. This was adjusted on the ground so that each plot was deliberately located within the existing gaps in the undergrowth, provided units were at least ten meters from the forest edge, and not closer than about 15 meters apart. For each plot, the number, size class, and species of trees that within each plot was recorded. The forest types around lake Bhangazi area include Swamp forest, Northern Dune forests and Northern Coastal Forests. The proposed development occurs in the later forest type only. No red data plants species were found in the forest, however four species of protected tree in terms of the National Forests Act are present within the study area. This affects only one of the accommodation units (7a) where two large Marula trees occur. It is recommended to leave out this unit , as well as unit 7b, to allow for better spacing between units. Three forest dependent red data mammals were seen using the forest. These include Tonga Red Squirrel (Paraxerus palliates tongensis), listed as endangered; Samango Monkey (Cercopithecus albogularis), listed as vulnerable ; Red Duiker (Cephalophus Natalens) , listed as least concern. Two forest depended red data birds were seen in the area including Southern Banded Snake-Eagle (Cicaetus cinerascens) and, Crowned Eagle (Stephanoaetus coronatus), both listed as near threatened. It is not believed that the development will have any significant impacts on these animals, although it is recommended that a survey be conducted in the forest for any potential nesting sites of the latter two species, before development proceeds. The impacts to trees in the top disturbed section (old fisherman’s camp) should be very low, as there should be no need to remove any trees. These trees contribute enormously to the aesthetics of the camp. Some of these trees are also on the protected tree list (see table 5). The impacts within the greenfield section of the forest will depend to some extent on how carefully the platforms are positions and constructed within the existing gaps in the forest undergrowth. Although the forest is intact , there is evidence of historical disturbance in the form of limited undergrowth clearing, probably for campsites. Using a 10-meter square plot for each accommodation unit, it was approximated that for at least half of the units, the removal of at least one or two tree(s) with a stem circumference of 60 cm (or stem diameter of 180 mm) will be required. Most plots will require some pruning and or removal of smaller trees and saplings. It is not believed that this will have any significant lasting impact on the forest integrity.

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1 Introduction

1.1 Understanding of brief The Bhangazi Community Trust proposes to develop a cultural tourism lodge within the designated area of the Bhangazi Heritage Site. A large portion of the project area has already been disturbed as an old fishing holiday camp. There is an extension of that footprint area, required for the development of the Bhangazi lodge accommodation units, into the neighbouring forest (greenfield section). Before the proposed project can begin, environmental authorisation must be obtained in terms of the Environmental Impact Assessment (EIA) Regulations of the National Environmental Management Act (No 107 of 1998, as amended) (NEMA). The proposed project triggers listed activities in terms of the NEMA EIA Listing Notices 1 and 3 (GNR. 983 and 985) and therefore requires the completion of a Basic Assessment (BA). As the project is proposed to take place within a World Heritage Site, the National Department of Environmental Affairs is the designated Competent Authority. This report comprises a specialist study to be included as part of the Basic Assessment report, to be done by a forest ecologist, and that addresses the requirement of DAFF, that among other issues, ‘a vegetation study be commission to highlight the quantity and species of trees that need to be trimmed or removed to accommodate the development’.

1.2 Legal context The main Acts of relevance include:

• World Heritage Convention Act, 1999 (Act 49 of 1999).

• National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA).

• National Environmental Management: Protected Areas Act, 2003 (Act 57 of 2003).

• National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004).

• National Heritage Resources Act, 1999 (Act 25 of 1999).

• KwaZulu-Natal Heritage Act, 2008 (Act 4 of 2008).

• National Forests Act, 1998 (Act 84 of 1998).

• National Water Act, 1998 (Act 36 of 1998).

• Marine Living Resources Act, 1998 (Act 18 of 1998).

• Seashore Act, 1935 (Act 21 of 1935).

• Maritime Zone Act, 1994 (Act 15 of 1994).

• National Environmental Management: Integrated Coastal Management Act, 2008 (Act 24 of 2008).

• National Environmental Management: Waste Act, 2008 (Act of 59 2008) Of importance to this report, is the National Forests Act, 1998 (Act 84 of 1998). Section 18 (a) , that refers to ‘natural forests must not be destroyed, save in exceptional circumstance’…’ and that trees within a natural forest may not be cut, destroyed, damaged or removed’.

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1.3 Layout and geo-referencing of lodge accommodation units The layout plan provided by the client, (see figure 1) was used with google earth satellite imagery, to locate and geo-reference units on the ground. Each unit within the forest (greenfield section) was designated by an alpha-numeric code from 1a to 11a, for the 2 bed units, and 1b to 6b, for the 4 bed accommodation units. A photograph and GPS pin drop using google maps was taken at each unit’s approximated 10 x10 meter plot. Each plot was marked on the ground using a white masking tape band around one of the trees near the centre, (see table1, of GPS points for each plot). Because the layout plan provided by the client was conceptual,(i.e. has not been surveyed on the ground), the location of each plot on the ground could not be exactly determined accuracy. Effort was made to locate each plot in the most open areas, provided it met the constraints that each unit not be closer than about 15 meters apart and that they were at least 10 meters from the forest margin . Using these assumptions, the total footprint of all the accommodation units in the green fields section is (11 x 10 + 6 x 10 ) i.e. 1160 square meters. A mitigation measure to reduce these impacts has been suggested in the revised report to both reduce the size of each units footprint from 10 meters square to 8 meters square as well as reducing the total number of units so that the total accommodation footprint is reduced to 970 m2 Table 1 Approximated geographic coordinates for accomadtooon units in the forest. (note: acuracy of geolocation, using google maps under a forest canopy is unknown)

Unit code South East Unit code South East

1a 28 08 21 32 32 34 1b 28 08 22 32 32 34

2a 28 08 15 32 32 38 2b 28 08 23 32 32 35

3a 28 0816 32 32 37 3b 28 08 23 32 32 35

4a 28 08 18 32 32 37 4b 28 08 24 32 32 35

5a 28 08 24 2 32 36 5b 28 08 24 32 32 36

6a 28 08 18 32 32 36 6b 28 08 24 32 32 37

7a 28 08 19 32 32 36

8a 28 08 20 32 32 36

9a 28 08 21 28 32 36

10a 28 08 23 28 32 35

11a 28 08 23 32 32 35

Main complex

28 08 22 32 32 35

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Figure 1 Layout plan of the proposed lodge. (The plot alpha numeric code was used in table 9 to described trees impacts).

1.4 Tasks and approach used The key task was to provide an objective study of the impacts to the forest by the placement of the planned accommodation units within the forest (greenfield section). To do this, an assumption had to be made that the accommodation units would consist of tented camps placed on elevated platforms that would occupy a standard 10 x 10-meter plot. The main restaurant complex, also planned for the green fields section, was assumed to be 25 x 25-meter plot. Each plot was deliberately located within the most open area of the forest that satisfied the constraints that units should be within the 15 m contour, at least ten meters

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from the forest edge and not closer than about 15 meters apart. For each plot, the number, size class and species of trees that fell within each plot footprint was recorded. Tree identification was facilitated by ‘The TreeApp South Africa, (2018) and Boon (2010). Tree species were identified to the best of my ability, but there is the possibility that some trees may have been incorrect identified. A list of tree species identified in this, and the biodiversity study is provided in appendix1. The tree diversity of these forest is exceptionaly high, and this list is by no means complete.

Figure 2 Plots were located as far as possible in existing openings. Alpha-numeric codes were given to each plot and marked by attaching tape to the largest tree within or close to the plot. Bottom left notice the open patches within forest undergrowth.

The following tasks, described in table2, below, were addressed in this report.

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Table 2. Tasks and the approach taken

Task Approach

1. Description of vegetation communities potentially impacted by the proposed lodge

Site visit. Google earth mapping Literature review

2. Assess the status of plant species of concern confirmed to occur in the study area, and comment on the likelihood of occurrence of other such species

Site visit. Literature review Interviews with local community members working in the area.

3. Assess the integrity of the vegetation communities, including current impacts and whether the vegetation is benefiting from the protection status of the area

Site visit. Literature review Interviews with locals

4. Determine whether forest adjacent to the lakeshore wetlands qualifies as Riparian Vegetation according to DAFF Wetland Delineation Guidelines, and if so, indicate Riparian Vegetation boundary.

Site visit. Literature review. Google earth mapping

5. Description of proposed project impacts on forests, and suggested mitigation measures

Site visit. Review of project plans and interviews with developers and consultants. Use of 10 x10 m plots for accommodation and 25 x25 m plot or the main complex

6. Description of the number and types of trees that will be impacted by the proposed development (list >60 cm circumference)

Filed work. Approximated location of each accommodation unit within the forest using google earth maps.

7 Report writing Home based

2 Description of vegetation communities potentially impacted by the proposed lodge

The Park is located at the southern end of the Maputaland Centre of Plant Endemism, part of the Maputaland-Pondoland-Albany biodiversity hotspot. There is enormous diversity of habitat and vegetation types within the Isimangaliso wetland park . Mucina and Rutherford (2006) classify the main forest types around lake Bhangazi as Northern Coastal Forest (FOz 7) and Northern Dune forests (AZd4). (see figure, 3 below)

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Figure 3 The natural vegetation in which the proposed lodge is to be situated consists primarily of Northern Coastal Forest (FOz 7) according to Mucina and Rutherford (2006).

Figure 4 Habitat and vegetation types within the lake Bhangazi study area: Mapululand Dune forest (back ground); Low land coastal forest (middle right, where lodge accommodation is planed ); hydrophilic grassland- scrub , (foreground) and Subtropical Freshwater lake.

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The vegetation communities within the broader study area are described below. Only the coastal forest habitat , where the accommodation units are planned will be impacted. It is unlikely that any other vegetation communities in the study area will be impacted. Subtropical Freshwater Wetlands These freshwater lakes are in areas of low relief in large depressions on the landward side of the coastal dune barrier. They are fed from relatively small catchments and maintained largely from ground water seepage. The lakes are nutrient-poor because of the predominantly sandy, leached nature of their substrates. Tall and short hydrophilic grasslands These habitats may be dynamic and change according to fluctuating water levels, fire and herbivory, they include grasses, sedges, reeds, and shrubs. Transition zones and ecotones The line of transition between the forests, and the wetland areas, are remarkably sharp. With dominant forest edge species such as Brachylaena discolor , Vepris lanceolate, and Albizia adianthifolia the forest margin is clearly healthy and intact. Occasional inundation of the grasslands adjacent to the forest, as well as occasional fires, prevents establishment of trees in this zone. Since the soils are pale and sandy, it is apparent that it is seldom, if ever, wet for long enough for organic material to accumulate and thus this ecotone between the forest and the lake consists of hygrophilous grasslands, rather than a wetland. These grasslands form a transition zone between the forests and the true wetlands around the lake edges. Dune forests Von Maltitz et. al, (2003) classifies this forest type as KwaZulu-Natal dune forests and are described as shrubby thicket to tall forest occurring along the KwaZulu-Natal coastline on the primary dune cordon inland from salt spray zone. These forests show a distinct gradient of change from the beach to the landward side of the dunes. Characterised by sandy substrata, rolling dune field topography, strong winds and adjacent to ocean beaches. Multi-stemming common and herb layer dominated by Isoglossa woodii. These a species rich forests with many tropical and subtropical species reaching their southern distribution limits along north-south gradient. Two main gradients are found in the dune area, a gradient from the coast inwards and a gradient from mature to secondary stands. High forest communities of mature stands are dominated by Sideroxylon inerme and are about 16m in height. By contrast coastal thicket is dominated by Euclea schimperi and Eugenia capensis and is only a few meters tall. Multistemmed trees are the norm. Natural disturbances include dramatic storms during summer, as well as fire, wind, and slumping of unstable dune sand substrate. The high degree of salt spray and strong winds help to shape the structure and species composition of the dune forest. Potential recruitment bottlenecks and arrested succession caused by dominant herb layer (esp. Isoglossa woodii). Slash and burn agriculture has played an important role in the current community structures, and more recently dune mining is a major man induced disturbance to this vegetation type. Northern Coastal Forest Von Maltitz et. al (2003) classifies the forest type where the lodge accommodation is planned , as ‘KwaZulu-Natal Coastal Forests’, while Scots-Shaw (2011) refers to them as ‘Maputaland Moist Coastal Lowlands Forest’ and has listed them as being “Endangered”. They are described by Von Maltitz et. al, (2003). As “ Medium to tall, species rich forest closely associated with the flat to rolling topography of the coastal lowlands of KwaZulu-Natal in form of small-sized patches - remnants of formerly dominating vegetation type of the region. These forests occur in the immediate hinterland of coastal dunes or on free-draining

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deep sands of the Maputaland coastal plain. Many tropical species reach their southern distribution along the affected range. Typically dominating canopy and sub-canopy layers are found in trees such as Albizia adianthifolia, Dyospyros inhacaensis, Drypetes arguta, Dyospyros natalensis, Englerophytum natalense, Protorhus longifolia, Teclea gerradii Manilkara concolor. Shrub layer and synusiae of climbers are well-developed, dense and rich in subtropical elements. Disturbance events include fire, large animals, cyclones and tornadoes. Iron-age farmers cleared much of the forest for agriculture. At present they are highly susceptible to alien plant invasion, of concern in many areas is Chromolaena odorata.

3. The status of plant species of conservation concern occurring, and potentially occurring in the study areas.

The iSimangaliso Wetland Park lies within the Maputaland Centre of Endemism (van Wyk and Smith, 2001) which, in turn is a part of the Maputaland-Pondoland-Albany Biodiversity Hotspot. The iSimangaliso Wetland Park Integrated Management Plan (2000), states that 2185 plant species have been recorded in the Park. These represent 9% of the flora of South Africa and 31% of the flora of KwaZulu-Natal. A total of 44 species are endemic to the region and three species are known to occur only within the Park. It is not known if these species occur within the study site. Four species which are protected in terms of the National Forests Act are present within the study area (see table 5, below). Examination of the Protected Tree Species list suggests that it is possible for several other protected tree species to occur within the greater project area, these are given in table 6 below. Table 3 Protected trees identified within the project area, along with their conservation status

Scientific name

Common name Conservation status

Sideroxylon inerme White-milkwood Least concern

Mimusops caffra Coast Red-milkwood Least concern

Sclerocarya birre Marula Least concern

Ficus trichopoda Swamp Fig Least concern

Table 4. Protected trees that may potentially occur within the greater project area , along with conservation status

Scientific name Common name Conservation status

Warburgia salutaris Pepper-bark tree Endangered

Prunus africana Red stinkwood Vulnerable

Pittosporum viridiflorum Cheese wood Least concern

Podocarpus falcatus Yellow wood Least concern

Cleistanthus schlectheri False tamboti Least concern

Although none of the below plants were positively identified to occur within the project site, based on their occurrence within similar vegetation types, or plant distribution modelling SANBI, 2017), there is a small possibility that some may occur in, or near the project site. See table 6 and 7 , below.

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Tale 6 Rare plants occurring within the broader Lake Bhangazi area, but not necessary in the study site, based on forest type (from forest plant database developed by Berliner, 2009)

Forest Type Species Endemic Status Trend

Kwazulu-Natal Coastal Elaeodendron croceum No LC Declining

Kwazulu-Natal Dune Adenia gummifera No NT Declining

Kwazulu-Natal Dune Vanilla roscheri No NT Declining

Kwazulu-Natal Dune Elaeodendron croceum No LC Declining

Licuati Sand Newtonia hildebrandtii No LC Declining

Licuati Sand Combretum mkuzense No NT

Swamp Raphia australis No VU

Kwazulu-Natal Dune Aloe thraskii SA NT

Kwazulu-Natal Dune Bonatea lamprophylla SA VU

Kwazulu-Natal Dune Didymoplexis verrucosa SA VU

Table 5 Rare plants potentially occurring within the quarter degree square of Lake Bhangazi area (using rare plant distributing modelling done by SANBI)

Scientific name Conservation status

Brachystelma vahrmeijeri Endangered

Didimoplexus verrucosa ?

Knipofia leucocephala Critically Endangered

Searsia kwazuluana Vulnerable

Warburgia salutaris Endangered

4. The integrity of the vegetation communities The disturbed areas on the ridge consist of open areas and buildings situated amongst large mature trees, this is the site where the old Banghazi fisherman’s camp was located. The forest below is in good condition, showing very little signs of recent human disturbance, however, from a closer look under the canopy, it is apparent that human disturbance occurred, some time back. This can be seen in the form of clearings made in the undergrowth, probably for camp sites. There are also several strange concrete and brick structures, including slabs, and a circular structure that may have been used for water storage, situated close to the big forest fig, where the main complex is planned (see figure 6). Alien plant infestation is very low, although a few individuals of two species of invasive alien plants were seen within the forest, these include, Chromeleana oderata, and Caesalpinia pulcherrima The forest margins along the north eastern fringe of the forest, facing the lake, are intact and in good condition (see figure below).

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Figure 5 Intact and healthy forest margins

The forest canopy, beneath where the lodge accommodation is planned, is 85-95 % intact. There are a few gaps, indicating possibly some historical disturbance associated with the camp site. There are numerous paths in the undergrowth made by, and still used by, hippos. There is also evidence of past human presence in the forest, as old litter such as old glass bottles, plastic and other non-degradable rubbish occur in a few places, supporting the idea that the forest may have been used as a camp site in the past (see figure 6).

Figure 6 Evidence of past human habitation in the forest. Litter, brick and concrete structures in the forest.

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Figure 7. Evidence of past clearing of undergrowth within the forest. Most of the accommodation units are in or close to areas that have had undergrowth cleared for campsites, some years ago. This is the sight of unit 1A.

Of interest, is the age of these coastal forests. The presence of well-established woodland species within the forest, such as Sclerocarya birre , Ziziphus mucronata, and Acacia kosiensis, more typical of woodlands and savannahs, than coastal forest, and the absence of many very large trees, seem to imply that these forests are of relatively recent origin, and that this area may have been a woodland prior to a forest. It is known that the extent of coastal and dune forest of the North coast have undergone significant changes during iron age hunter gatherer times, as well as more recently during the colonial period of forest exploitation and removal of local populations . For example, Weisser & Marques, (1979), have shown, using air-photos, that the coastal strip between Richards Bay and the Mfolozi River, was mature Acacia karroo Woodlands in 1937, but was replaced by Secondary Dune Forest by 1974. The causes of these changes probably lie in changes in human impacts brought about by the assumption of control of the area by the Department of Forestry from about 1949. Under this and later the apartheid regime local populations were forced out of the area, resulting in a decline in livestock, a decline in fires and a halt to clearing for cultivation, thus allowing forest succession.

5. Can the forest be considered as riparian vegetation ? To delineate any wetland the following criteria are used by the Department of Water Affairs. A practical field procedure for identification and delineation of wetlands and riparian areas, make use of the following criteria (DWAF, 2005):

• Wetland (hydromorphic) soils that display characteristics resulting from prolonged saturation such as grey horizons, mottling streaks, hard pans, organic matter depositions, iron and manganese concretion resulting from prolonged saturation;

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• The presence, at least occasionally, of water loving plants (hydrophytes); • A high-water table that results in saturation at or near the surface, leading to

anaerobic conditions developing in the top 50 cm of the soil. • Topographical location of the wetland in relation to the landscape.

From the above criteria, these forests can neither be considered as riparian, or wetland vegetation. This is because the forests species are typical of coastal forests and not those typical of swamp or riparian forests. In addition, the grasslands adjacent to the forest are not true wetlands as evidence from the soil texture and colour. These areas are only occasionally flooded and for short periods, not sufficiently long enough to build up organic matter, characteristic of wetland soils (see biodiversity study, Terratest, 2018) . True wetlands occur further down the slope. 5 Description of proposed project impacts on forests, and suggested mitigation

measures The mitigation hierarchy should be followed at all stages of the project, see figure below.

Figure 8 The mitigation hierarchy to manage biodiversity impacts

The impacts associated with the development within the greenfield section, as well as recommended avoidance and mitigation measures are presented in table 8, below.

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Table 6 Impacts associated with the construction of lodge accommodation within the forest. Avoidance and mitigation strategies are recommended to minimize residual impacts. The assumption is made that the footprint of accommodation units are 10 square meters and structures to be built on elevated wooden platforms. Refer to table 8 for more details.

Activity Impact Avoidance Mitigation Residual impact

Construction of platforms for tented camps

Removal of trees that are in footprint. Loss of canopy cover integrity Loss of understory cover, small increased risk of erosion

As far as possible build flexible structure shapes to fit around larger trees Placing of platforms in old camp sites, with open understory

Enrichment planting of similar trees removed during construction, by planting nursery grown out tree , as close to where they were removed

Short term: increased light penetration into forest, changes in run-off Medium term: negligible as forest will recover as canopy closes over light gaps.

Construction of footpaths in forest

Possible soil compression, increased risk of soil erosion

As far as possible use current hippo paths

Use elevated boardwalks

Short term: Hippos may not be happy but will adapt their foraging behaviour. Medium term: negligible

Vegetation disturbance & increase human traffic

Increased risk of alien invasive plant spread Possible disturbance of local bird and wildlife populations Possible nesting site of Southern banded snake eagle (heard calling inside forest)

Minimise construction footprint, and need for vegetation removal (reduce number of units and only build where prior clearing of understory has occurred) Survey for possible nesting sites. Monitor rare and endangered fauna in area

Remove alien invasive plants during, and after construction, incorporate into an environmental management plan

The risk of alien plant spread negligible if managed. Short term: some wildlife may be scared off Medium term: wildlife adapts, some species attracted to modified habitats, some leave.

Permanent presence of humans in or close to wildlife habitats

Increased human wildlife conflicts in an unfenced camp (hippos, buffalo, monkeys, bush pigs etc)

Electric fence around camp Strict control of refuse.

Create awareness to visitors not to feed wildlife

If managed, residual impacts are negligible

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6. Description of the number and type of trees impacted by the proposed development.

6.1 Forested section (greenfield) To facilitate a comparative assessment, the assumptions were made that each accommodation unit has a footprint of 10 square meters; that units will not be closer than 15 meters apart; and that units will be placed at least 10 meters away from the forest edge, inside the forest . Table 8, below, provides a summary of the extent to which lodge accommodation may impact on trees. Of interest is how many, if any, larger trees with a stem circumference of 60 cm or more (equivalent to a stem diameter of 180 mm) would need to be removed. To some extent, this depends on how the construction of the platform is done, as some of the tree removals may be avoidable with careful placing of the platforms. Table 7 . Impact of lodge accommodation, on forest tree species. Three tree size classes were used. Note that large trees were considered as those with a stem circumference > 60 cm (equivalent to a stem diameter of 180 mm)

Development section

Number of trees in 10 x 10 m plot with stem circumference (cm)

Other species present

10-29 30-59 >= 60 Species > 60

Lodge accommodation (11X2)

unit 1 a 4 3 2 Diospyros natalensis Clerodendron glabra

Vepris lancelota Ziziphus mucronata

unit 2 a 0 4 0 Sersia nebulosa Grewia occidentalis Strichnos Gerradii

unit 3 a 8 0 0 Sclerocarya birrea, Trichelia emmitca

unit 4 a 7 1 0 Trichelia emmetica, Celtis African

unit 5 a 7 0 2 Celtis African, Clerodendron glabra

Vepris lanceolate, Ficus trichopoda

unit 6 a 15 2 1 Vepris lanceolate Celtis African, Clerodendron glabra, Grewia occidentalis Strichnos Gerradii

unit 7 a 10 0 2 Sclerocarya birrea

Diospyros natalensis; Harpephyllum caffrum

unit 8 a 7 0 0 Clerodendron glabra, Albizia adianthifolia, Strichnos gerrradii Protorhus longifolia

unit 9 a 8 0 1 Trichelia emmetica

Diospyros natalensis Clerodendron glabra Albizia adianthifolia

unit 10 a 6 2 1 Trichelia emmetica

Clerodendron glabra Diaspyros natalensis

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Celtis Africana Ficus trichapodia Ficus craterostoma Hyphaene coriacea Brachylaena discolour

unit 11 a 4 4 2 Albizia adianthifolia Sersia natalensis

Clerodendron glabra Diaspyros natalensis Sersia nebulosa

Lodge accommodation (7 x4)

unit 1 b 3 4 0 Euclea natalensis Albizia adianthifolia

unit 2 b

2 Albizia adianthifolia Protorhus longifolia

Euclea natalensis

unit 3 b 5 2 2 Albizia adianthifolia Diaspiros natalensis

Clerodendron glabra Brachyleana discolour Celtis Africana

unit 4 b 10 4 0 Albizia adianthifolia Diaspiros natalensis Brachylaena discolour

unit 5 b 9 4 0 Brachylaena discolour Searsia nebulosi Searsia gueniensis

unit 6 b 6 0 1 Protorhus longifolia

Brachylaena discolour Ziziphus mucronata

unit 7 b Could not fit in, leave out

Main complex (plot 25x25)

10 6 3 Albizia adianthifolia Celtis Africana Trichelia emmitica

Ficus craterostoma Hyphaene coriacea Trichelia emmitica

Note: Plots 11 a and 1b fall very close to each other and the main complex , and it is suggested that these units are left out of the plans.

6.2 Disturbed areas, with existing structures

The old fishing camp comprises of disturbed areas, with several open patches and existing structures, in various states of disrepair. Many large and beautiful trees occur in and around almost all these structures. Many of these trees are protected species. The trees occurring in these sections, are mostly around the edges , and it should not be necessarily to remove any of these trees. In some cases, minor pruning may be required. The large trees within this section include: Syzygium cordatum, Trichelia emmitica, Ficus craterostoma, Celtis Africana, Sclerocarya birrea; Apodytes diminuta, Protorhus longifolia, Mimusops caffra Sideroxylon innerme, and a large exotic Ficus spp.

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Reception area

Figure 9.The proposed reception area , with two large water-berry trees on the edges of the plot

Trails camp (4x2 units)

Figure 10 Proposed trails camp area with existing structure, surrounded by a large marula that may need to be pruned

Senior staff camp (5x2 units)

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Figure 11 Proposed senior staff camp on old disturbed areas with building in a state of disrepair, surrounded by figs and white stinkwoods

Access and Parking area

Figure 12 The proposed parking area has large opens spaces, with old buildings interspaced with several large and medium size trees

Community gathering area

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Figure 13. The proposed community gathering area has a large open space with several large water-berry and Natal mahogany trees on the edges

7. Concluding remarks The impacts associated with the proposed Bhangazi lodge development are considered separately for, the top section , where areas that have already been disturbed and partially cleared for buildings, (associated with the old fisherman’s camp); and the greenfield section, inside the forest, where the lodge accommodation units and main complex are planned. The impacts to trees in the top section should be very low, as no trees need to be removed . There may be a need for some pruning. The trees in this section are large and contribute enormously to the aesthetics of the camp. Many of these trees are also on the protected tree list (see table 5). The impacts within the greenfield section of the forest depend on the following: a) The time scales over which impacts are considered. In the short term the construction will result in some loss of understory and possibly minor gaps in the canopy, in the medium term, (5 years, or more) the forest will recover, and gaps, if any, in the canopy will close over. c) Diligence in applying avoidance and mitigation measures during construction, (as recommended, in table 8) can significantly reduce impacts, by minimizing the need to remove the larger trees within the forest. Careful placement of unit platforms within existing understory gaps will be essential. It is recommended that a forest ecologist be present when the sites are surveyed and laid out. It is approximated that about just over half of the units within the greenfield section of the development, may need to have at least one, or more trees, with a stem circumference of

60 cm or more (equivalent to a stem diameter of 180 mm), removed. In all cases, except for

the main complex, there are never more than two trees, (larger than 60 cm ) that fall within the approximated footprint (see table 8). None of these trees, apart from the two large Marula trees in unit 7a, are protected or endangered. The Marula tree being a national protected tree species (DAFF, 2017). The main complex was approximated to be 25 x 25 meters in size, and located close to a large forest fig. The impressive tree should be used as the central focus around which the

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deck of the restaurant complex can be built. It is estimated that at least 3 trees with a stem circumference of more than 60 cm, may need to be removed to build this complex. These include Albizia adianthifolia, Celtis Africana; and Trichelia emmitica . None of these trees are endangered or protected and occur in abundance in the forest. To reduce the footprint and to ensure a reasonable space between units, it is recommended that accommodation units be reduced by two units. Unit 7a has two large Marula trees that should not be cut down, while unit 7b , falls too close to the main complex to fit in comfortably. In addition, changes to shift the restaurant complex and pool area from the Greenfields section to the existing disturbed areas of the fishmen as camp need to be considered Section 18 of the National Forests Act, (Act 84 of 1998) states that ‘natural forests must not be destroyed save in exceptional circumstances. Although this development will result in some loss of forest trees, the forest will certainly not be destroyed, and apart from some understory clearing, will recover fully within a few years, (provided the structures are on elevated platforms, made of wood, and all paths in the forest consist of elevated boardwalks). In addition, the units must be placed, as far as possible, in areas where the understory had been cleared before and is still relatively open. Low density- low impact ecotourism is a valid form of sustainable use of natural forests. The placement of the accommodation units within the forest, (rather than on top of the ridge) will significantly improve the marketability and quality of the nature experience of the lodge. This will also allow good views of the lake and the surrounding grasslands that are utilised by game (buffaloes, hippos, waterbuck and kudu etc). There is also the urgent need for the land claimants, the Bhangazi community, to realise economic benefits from their land. This particularly, in the face of mounting pressure to mine rare minerals within this area, as such, all efforts must be made to promote ecotourism as an alternative and sustainable form of land use to sand mining. Updated impact footprint plan

As a proposed mitigation on the footprint of the Greenfields section amendments to the

impact footprint has resulted in a generalised decrease in impact on the Greenfields sections ,

these changes are listed in the table below.

Mitigation Measure Nett Result

Remove proposed new access road, in

favour of using the existing access road

to the fishing camp area.

No longer need to clear an extent of

200m2 (forested area) for the access road

alignment.

Relocate restaurant and pool complex

from forest zone to disturbed fishing

camp zone.

No longer need to clear an extent of 350

m2 (forested area) for the restaurant and

pool complex.

Following above, no requirement for

new access road leading to restaurant

complex.

No longer need to clear an extent of 200

m2 (forested area) for the service road

alignment.

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Reducing the size of the proposed 2 and

4 bed chalet units from 75 m2 to 50 m2

and 40 m2 respectively.

Potentially cleared area reduced from

1350 m2 to 970 m2 (footprint of raised

decks, not necessarily clearance of forest

canopy).

Forest infrastructure limited to chalets

and boardwalks only, all on raised

timber decks.

Reduction of impact on undergrowth.

These changes do not impact significantly on the result of this report, but are in line with the

recommendations made in this report to reduce the impact on the greenfield section by

reducing the total number of accommodation units as well as shifting the restaurant and pool

complex from the green fields section to the disturbed areas of the fishing camp. This will

make a significant reduction in the need to disturb the forested area.

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References Berliner D.D, 2009 .Systematic Conservation Planning for South Africa’s Indigenous forest. PhD. Thesis, University of Cape Town. Boon, R. 2010. Pooley’s Trees of Eastern South Africa. Flora and Fauna Publications Trust. Botanic Gardens Road, Durban. DWAF. 2005. A Practical Field Procedure for Identification and Delineation of Wetlands and Riparian Areas. Department of Water Affairs and Forestry. Private Bag X 313 Pretoria DAFF, 2017 National List of protected trees. Mucina L. and Rutherford, 2006) The Vegetation of South Africa, Lesotho and Swaziland. The TreeApp South Africa, 2018. Val Thomas, Google play store. Scott-Shaw C. R. (2011) KwaZulu-Natal Forest Map Methodology. Ezemvelo KZN Wildlife Biodiversity Research Division Internal Report. Queen Elizabeth Park, Pietermaritzburg. 8pp Terratest , 2018. Biodiversity study of the site for the proposed lake Bhangazi lodge. WPA, 2011. iSimangaliso Wetland Park Integrated Management Plan (2010 – 2016). ISimangaliso Wetland Park Authority. Private Bag X 05 St Lucia. 3936. [email protected] SANBI. 2018. Threatened species list of South Africa: General Information available on BGIS (www.bgis.sanbi.org) van WYK, A.E. and SMITH, G.F. 2001. Regions of Floristic Endemism in Southern Africa: A Review with Emphasis on Succulents. Umdaus Press. Hatfield. South Africa Von Maltitz, G.E., Mucina, L., Geldenhuys, C.K., Lawes, M.J., Eeley, H. and Adie, H. 2003. Classification system for South African indigenous forest: An objective classification for the Department of Water Affairs and Forestry. Pretoria: Council for Scientific and Industrial Research, Environmentek. Weisser P.J. & Marques F., (1979), Gross vegetation changes in the dune area between Richards Bay and the Mfolozi River, 1937—1974. Bothalia 12, 4: 711-721 (1979)

http://www.bgis.sanbi.org/

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Appendix 1: Recorded tree and vine species list

Scientific name Common name Scientific name Common name

Acacia kosiensis Dune Sweet Thorn Kraussia floribunda Rhino coffee

Acridocarpus natalitius Narrow-leaf Moth-fruit Lagynias lasiantha Smooth Pendent medlar

Adenia gummifera Green-stem Landolphia k irk ii Rubber Vine

Adenopodia spicata Spiny Splinter-bean Londolphia kirkii Sand apricote vine

Albizia adianthifolia Flatcrown Maerua nervosa Natal Bush-cherry

Allophylus natalensis Dune False-currant Mimusops caffra Coast Red-milkwood

Ancylobotrys petersiana Climbing Milk-apricot Monanthotaxis caffra Dwaba-berry

Antidesma venosum Tassel-berry Ochna barbosae Sand Ochna

Apodytes dimidiata White-pear Ozoroa obovata Coast Resin-tree

Bersama lucens Glossy White-ash Pavetta gerstneri Zulu Brides-bush

Brachylaena discolor Coast Silver-oak Pavetta natalensis Coast Brides-bush

Bridelia cathartica Blue Sweet-berry Peddiea africana Poison-olive

Canthium inerme Turkey-berry Phoenix reclinata Wild Date Palm

Capparis brassii Narrow-leaf Caper bush Pittosporum viridiflorum Cheeze wood

Catunaregam obovata Coast Bone-apple Protorhus longifolia Cape beach

Celtis africana White stinkwood Psydrax locuples Sand Quar

Clausena anisata Horsewood Psydrax obovata Quar

Clerodendrum glabrum Tinderwood Ptaeroxlyon obliquum Sneezwood

Cussonia zuluensis Zulu Cabbage-tree Rapanea melanophloeos Poison-olive

Diospyros natalensis Acorn berry tree Rhoicissus digitata Five-finger Grape

Dovyalis longispina Coast Kei-apple Rhoicissus digitata Five-finger Grape

Dovyalis rhamnoides Sourberry Kei-apple Sclerocarya birrea Marula

Dracaena hookeriana Large-leaf Dragon-tree Sclerocroton integerrimum Duiker-berry

Drypetes natalensis Stem-fruit Ironplum Scutia myrtina Cat-thorn

Ekebergia capensis Cape-ash Searsia natalensis Northern Dune Currant

Englerophytum natalense Natal Milkplum Searsia nebulosa Coast Currant

Erythroxylum emarginatum African Coca-tree Sideroxylon inerme White-milkwood

Euclea natalensis Hairy Guarri Strelitzia nicolai Natal Wild Banana

Ficus burtt-davyi Scrambling Fig Strychnos gerrardii Coast Monkey-orange

Ficus craterostoma forest fig Strychnos mitis Pit-leaf Bitterberry

Ficus lutea Giant-leaf Fig Strychnos spinosa Green Monkey orange

Ficus natalensis Coast Strangler Fig Synaptolepis k irk ii Dream Herb

Ficus trichopoda Swamp Fig Syzygium cordatum Umdoni

Garcinia livingstonei African Mangosteen Tarenna junodii Climbing Tarenna

Grewia caffra Climbing Raisin Teclea gerrardii Zulu Cherry-orange

Grewia occidentalis Cross-berry Raisin Tricalysia delagoensis Tonga Jackal-coffee

Gymnosporia arenicola Dune Spikethorn Tricalysia sonderiana Coast Jacka;-coffee

Gymnosporia nemorosa White-spot Forest Spikethorn Trichilia dregeana Forest Natal Mahogany

Harpepyllum caffrum Wild plum Uvaria caffra Small-fruit cluster-pear

Hymenocardia ulmoides Red-heart Tree Vangueria infausta Velvet Wild-medlar

Hypaene coriacea Lala palm Vepris lanceolata White-ironwood

Voacanga thorsii Wild frangipany

Xylotheca kraussiana African-dogrose

Zanthoxylum capense Small Knobwood

Ziziphus mucronata Buffalo-thorn

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